Response to cP on GLs Guidelines on harmonised definitions and templates for funding plans of credit institutions
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On template P05.00: The instructions on template P05.00 indicate that when instruments move from one category to another, including phased-out AT1 instruments becoming fully eligible T2 instruments, the instruments should be registered as an outflow in the Maturing (gross outflows)" of the corresponding original instrument category and as an inflow in "Non-retained issuance (gross inflows)" of the corresponding new instrument category."
1.1 Do respondents agree with the proposed breakdown of “Total long-term unsecured (original maturity >=1 year)”?
No1.2 Otherwise, which breakdown would you suggest?
NoTemplate 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?
No3.1 Do respondents agree that information on currency breakdown after hedging (template P02.06) will provide effective insight into possible currency mismatches?
Currency breakdown after hedging could be only properly interpreted with the inclusion of off balance sheet items (FX swaps, for expample).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?
Only covered bonds can be retained, for all other categories this line should be deleted.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?
Yes6.1 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?
No.On template P05.00: The instructions on template P05.00 indicate that when instruments move from one category to another, including phased-out AT1 instruments becoming fully eligible T2 instruments, the instruments should be registered as an outflow in the Maturing (gross outflows)" of the corresponding original instrument category and as an inflow in "Non-retained issuance (gross inflows)" of the corresponding new instrument category."