Association for Financial Markets in Europe

A comprehensive template is preferred over providing detailed breakdown in EU CR5-B and EU CR6.
See Letter for more detail.
COREP
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Q3 & 4. Would provide a detailed view of a bank’s book profile, which is a point in time view of a bank’s business plan and considered proprietary and market sensitive.
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Q3 & 4. Would provide a detailed view of a bank’s book profile, which is a point in time view of See a bank’s business plan and considered proprietary and market sensitive.
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We have concerns over the feasibility of providing this information given the scenario and probabilistic nature of IMM exposure calculations.
See Letter for more detail.
Please see suggested alternate MR1-A template in letter.
We believe the scope of application should remain limited to G-SIIs and O-SIIs and national authorities should not have the discretion to apply more widely. In addition, we believe it necessary to ensure the Guidelines do not contradict Article 13 that limits the disclosures regarding significant subsidiaries. Furthermore, we believe a seperate disclosure of non-deducted insurance participation should not be required.
See Letter for more detail.
We are supportive of a template, but believe the BCBS Phase II consultation on Pillar 3 should be finalised and form the basis of future consultation on the structure and detail of the template.
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Disclosure in an editable format is feasible, however, it will be difficult to achieve in the timeframe outlined. As such, we believe this requirement should form part of a future consultation, allowing firms to first concentrate efforts on ensuring compliance with the revised Pillar 3 framework and the CRR,
See letter for more detail.
No, given templates are still being consulted on, and the EBA subsequently will require time to finalise the guidelines, the final form of templates is unlikely to be finalised earlier than late 2016. This will leave insufficient time to follow due process without significant disruption to other year-end reporting obligations.
See letter for more detail.
See Letter for detail.
Sahir Akbar
A