In general we recommend to reduce the disclosure requirements and only show aggregated key figures as already stated in Part B. Nevertheless, when comparing both solutions we prefer Template EU OV1-B instead of CR5-B or EU CR6.
Beside our general concern about the granularity the disclosures shall have, we prefer a matching to the COREP data however only on an aggregated level.
We do not comment on this question as we do not use IRB approach. However, please consider our general concerns regarding the granularity of future disclosures.
We do not comment on this question as we do not use IRB approach. However, please consider our general concerns regarding the granularity of future disclosures.
As already stated above we strongly recommend reducing the disclosure requirements in general as well as their granularity. Any further extension in our view does not add actual value; therefore no further breakdown should be required regardless of the risk type.
As already stated above we strongly recommend reducing the disclosure requirements in general as well as their granularity. Any further extension in our view does not add actual value; therefore no further breakdown should be required.
Due to the absence of market risk in our business we have no problem with the current disclosure requirements regarding market risk. However, also here further reduction of information details should be considered.
We see no further benefit of the additional disclosures as proposed. Thus, please do not implement any intended separate disclosures. Once again, we strongly recommend reducing the disclosures instead of blowing them up.
Please clearly limit the scope of application to G-SII, O-SII and any other institution on basis of supervisory decision and do not use expressions like “all institutions” which could be misinterpreted. We strongly recommend not expanding the scope of application - neither now nor in the future - to other institutions which are obliged to disclose certain information according to Part 8 of CRR.
We see no further benefit of the additional disclosures as proposed. Thus, please do not implement any intended separate disclosures. Once again, we strongly recommend reducing the disclosures instead of blowing them up.
As already stated above, we strongly urge to reduce the disclosure requirements as we do not see any additional value in an extended disclosure framework. This particular adjustment of editable formats of disclosures bears the risk that disclosures are modified by third parties without any authorisation and knowledge of the related institution.
As we disagree to the approach of Q11, we strongly reject any quantitative information disclosed under an editable format.
We disagree to the enhancements in total as such we also disagree to an early implementation of any selected set of information. It adds more complexity and increases the implementation efforts substantially. Any adjustment on the disclosure framework has to be implemented with a reasonable implementation phase-in.
We disagree to any earlier application due to increasing requirements, irrespectively of the necessity of additional information at all.
We do not have comments on specific parts. In general, we once again want to point out that in our view the massive enhancement of the disclosure requirements proposed overshoot the mark of comprehensive information for the public. In addition, the legal basis for certain adjustments is at least unclear.
As already stated in Part B the implementation of any additional disclosures will add additional burden to implement, prepare and to disclose while the added value for the public is at least doubtful. Thus, we recommend to reassess and review the draft guidelines and in this line we strongly urge to reduce the disclosure requirements instead of increasing them as the EBA intents to do.
We are happy to respond on the implementation effort on a revised and streamlined EBA proposal going forward which we urge the EBA to do in due course.
