We consider the proposed templates appropriate and we welcome they are aligned with reporting templates.
We suggest some adjustments (informed in the answer for Question 2 below) as, in our opinion, some breakdown as required considerably increases the reporting burden, especially for entities with a large number of subsidiaries while do not provide of significant information to the market and could even be counterintuitive and misleading to the market.
To minimize the cost of research for the financial statements´ readers, we would suggest the inclusion of references to the annual report and to Pillar 3 report to help readers in finding more granular information regarding exposure elements and how they are valued, as well as understanding of the elements that composes the exposure and how they relate to the banks´ business model.
In our opinion, there are no rows missing. In contrast, some granularity in the template could be eliminated since they do not provide additional relevant information. We propose that rows 10a and 10b, related to SFT exposures, be unified and the rows that detail off-balance exposures (rows 15a, EU-15.1a, EU-15-2a and 16a) be eliminated. We understand that such breakdowns do not add more useful information to the reader for the purpose of these templates.
We understand that a granular information should be provided for the consolidated basis and a summarized breakdown for the relevant subsidiaries. Only if necessary, more granular information could be disclosed for relevant subsidiaries regarding counterparties (LRSpl).
