Response to cP on GLs Guidelines on harmonised definitions and templates for funding plans of credit institutions

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1.1 Do respondents agree with the proposed breakdown of “Total long-term unsecured (original maturity >=1 year)”?

1.2 Otherwise, which breakdown would you suggest?

Template P02.02 has been expanded to include additional public sector and Central Bank sources of funding. Do respondent believe that now this template covers all forms of public sector and central bank sources of funding or should additional forms of sources be included?

3.1 Do respondents agree that information on currency breakdown after hedging (template P02.06) will provide effective insight into possible currency mismatches?

Please refer to our submitted letter.

3.2 Does the information reflect banks’ FX management approac more information to better reflect banks’ FX management?

Please refer to our submitted letter.

3.3 Are the instructions are clear enough?

Please refer to our submitted letter.

3.4 If the instructions are not clear please indicate how they could be improved.

Please refer to our submitted letter.

Do respondents agree with the possibility to have “retained issuance” for each of the instruments included in template P05.00? If not, could you please indicate which ones should be maintained and which ones should not and the reasons for it?

Please refer to our submitted letter.

5.1 Which methodology do you apply to calculate carrying amounts for future issuances (please describe as detailed as possible and highlight any problem with that calculation)?

Please refer to our submitted letter.

5.2 Are you of the opinion that reporting maturing and new issuance volumes (as defined in P 05.00) as nominal amounts would better reflect your planning procedure and approach and do you believe that this alternative is preferable?

Please refer to our submitted letter.

6.1 Do respondents believe that these movements could occur too often or be big enough so that including them as inflows or outflows as explained above and in the instructions may distort the analysis of the information?

Please refer to our submitted letter.

6.2 If the answer to the 6.1 is positive, which would be the best way for the respondents to report this information?

Please refer to our submitted letter.

7.1 Do respondents agree with amending the templates to align definitions with FINREP? Are there other definitions that could be further aligned with other parts of the EBA supervisory reporting framework?

Yes, we support the closer alignment of the definitions and templates with FINREP.

7.2 Do respondents agree that alignment of definitions will facilitate reporting production process?

Yes.

7.3 Are there other aspects in the template design or further integration with FINREP reporting technical package that could help in data production process?

We recommend that the submission date for all of the reporting templates is moved from 28 February to 30 April. Please refer to our submitted letter for more detail.

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Response to cP on GLs Guidelines on harmonised definitions and templates for funding plans of credit institutions

1.1 Do respondents agree with the proposed breakdown of “Total long-term unsecured (original maturity >=1 year)”?

1.2 Otherwise, which breakdown would you suggest?

Template P02.02 has been expanded to include additional public sector and Central Bank sources of funding. Do respondent believe that now this template covers all forms of public sector and central bank sources of funding or should additional forms of sources be included?

3.1 Do respondents agree that information on currency breakdown after hedging (template P02.06) will provide effective insight into possible currency mismatches?

3.2 Does the information reflect banks’ FX management approac more information to better reflect banks’ FX management?

3.3 Are the instructions are clear enough?

3.4 If the instructions are not clear please indicate how they could be improved.

Do respondents agree with the possibility to have “retained issuance” for each of the instruments included in template P05.00? If not, could you please indicate which ones should be maintained and which ones should not and the reasons for it?

5.1 Which methodology do you apply to calculate carrying amounts for future issuances (please describe as detailed as possible and highlight any problem with that calculation)?

5.2 Are you of the opinion that reporting maturing and new issuance volumes (as defined in P 05.00) as nominal amounts would better reflect your planning procedure and approach and do you believe that this alternative is preferable?

6.1 Do respondents believe that these movements could occur too often or be big enough so that including them as inflows or outflows as explained above and in the instructions may distort the analysis of the information?

6.2 If the answer to the 6.1 is positive, which would be the best way for the respondents to report this information?

7.1 Do respondents agree with amending the templates to align definitions with FINREP? Are there other definitions that could be further aligned with other parts of the EBA supervisory reporting framework?

7.2 Do respondents agree that alignment of definitions will facilitate reporting production process?

7.3 Are there other aspects in the template design or further integration with FINREP reporting technical package that could help in data production process?

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