Submission #5

AFME

1.1 Do respondents agree with the proposed breakdown of “Total long-term unsecured (original maturity >=1 year)”? Please refer to the document attached for our response to the consultation.

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? Please see file attached.

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

3.2 Does the information reflect banks’ FX management approac more information to better reflect banks’ FX management? Please see file attached.

3.3 Are the instructions are clear enough? Please see file attached.

3.4 If the instructions are not clear please indicate how they could be improved. Please see file attached.

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 see file attached.

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 see file attached.

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 see file attached.

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 see file attached.

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 see file attached.

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? Please see file attached.

7.2 Do respondents agree that alignment of definitions will facilitate reporting production process? Please see file attached.

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? Please see file attached.

Upload files EBA Funding Plans Consultation Response - May 2019.pdf

Name of organisation AFME