British Bankers' Association

The British Bankers’ Association (“BBA”) is the leading association for UK banking and financial services for the UK banking and financial services sector, speaking for over 220 banking members from 60 countries on the full range of the UK and international banking issues. All the major banking players in the UK are members of our association as are the large international EU banks, the US banks operating in the UK and financial entities from around the world. The integrated nature of banking means that our members are engaged in activities ranging widely across the financial spectrum encompassing services and products as diverse as primary and secondary securities trading, insurance, investment banking and wealth management, as well as deposit taking and other conventional forms of banking.

The BBA is pleased to respond to this consultation on the XBRL taxonomy.

We would refer you to the letter we wrote to the EBA dated 23rd September 2013, which we have included in this response for your convenience. This details our key messages for the EBA.

In addition, we have provided you with a separate document which contains some examples of validations that we have discovered which need further analysis. Please note this is not an exhaustive list. We have also included to this letter a separate annex which highlights other questions we would ask the EBA to consider.

We understand this is a challenging and technical task, but it nevertheless needs to be accurate in order to avoid critical difficulties when it comes to submission. The BBA would be very happy to gather members and support the EBA in its development of the XBRL taxonomy in the future.

Yours sincerely

Robert Driver

Policy Advisor
Prudential Capital & Risk
Tel: 020 7216 8813
British Bankers' Association