Submission #6

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Banco de España

Structural representation of taxonomy changes: Respondents are asked to consider if these arrangements will in fact provide them with any benefits, or if they believe an alternative possible implementation would generally be more beneficial. N/A

Tables utilising new layout features: Since both of these are features that happened not to have appeared in the previous version of the taxonomy (although they are within the ambit of the table linkbase specification) respondents are asked to consider if these layout features will cause them implementation problems. N/A

Taxonomy file version tags: Respondents’ views are sought on the relative value of each approach, or any reasonable alternative. N/A

Introduction approach: Respondents’ opinions are sought on any practical considerations as to the date of transition to remittance under the 2.1 sub taxonomies. N/A

General comments:

For columns 410-480 from C.06.00 table, where “capital buffers” are reported, COREP 2.1 taxonomy has created the following metric:
Eba_mi212: Risk weighted exposure

There is no background in the ITS or in the Directive 2013/36/EU for saying that these columns should show the risk weighted exposure related to the different buffers. Instead of it, ITS talks about “buffer requirements”

Clarifying this point, would avoid misunderstandings.

Using “risk weighted exposure” as the name of the metric could lead to misunderstandings, so it would be advisable to assign a more adequate metric, or to create one “ad hoc” for these buffers.

Changes would affect both versions of taxonomy (Table C.06.00, columns 410-480)

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Name of organisation Banco de España