German Banking Industry Committee

GBIC: The requested breakdown can be generated and includes all relevant senior unsecured instruments considered in the planning process. However, this advanced reporting will cause extra effort in various departments and group entities. A reconciliation of “long-term unsecured” to the other reporting requirements “Liability Data Reporting” to SRB will not be possible, as the definition “Debt Securities issued” does not include “promissory notes and covered bonds”, since they are part of regular liabilities.

Regarding the “maturity”, a residual maturity instead of an original one would be possibly more reliable, since a funding plan as well as a “NSFR” calculation (weighting) is based on residual maturities. A roll-down or maturing volume would be essential for it.
GBIC: No answer.
GBIC: The new template includes funding from central banks and promotional banks (KFW, EIB). However, funding from public authorities is not included in P02.02, but is shown in P01.02, Row 147. Only by combining those two would all forms of public-sector funding be considered in the funding plan.
GBIC: No, we disagree. The bank’s foreign currency loans/deposits are hedged to EUR on a portfolio basis; a breakdown into single loans/deposits is not possible or would, at most, only represent assumptions. Therefore, for these positions, all hedging activities must be included in a separate, dedicated FX hedging category, with one line for assets and one line for liabilities.
GBIC: Before proposing an additional information request, clarification of the definition of “currency mismatch” would be necessary, i.e. how is a currency mismatch exactly measured?
GBIC: Unfortunately not; more detailed instructions would be necessary.
GBIC: Please include exact FINREP references to FINREP data points in the format “Form.Colum.Row” especially for the reporting lines “050 Other Financial assets” and “110 other Financial Liabilities”. In addition to that, further information is needed on natural hedges.

It can be concluded from point 27 of the explanatory remarks on template P02.06.01 and the example included therein that the information requested on structural currency mismatches is to be provided not only for significant foreign currencies but also for the respective reporting currency. We fail to understand how currency mismatches in the (home) reporting currency can occur and should therefore be grateful for an explanation or clarification from the EBA in this regard.
GBIC: Since we may only use secured issuances for refinancing operations with central banks, only retained issuances for these categories seem to provide information.
GBIC: some of our members use nominal amounts for planning purposes.
GBIC: Yes, we believe so. Planning issues are better reflected with nominal amounts (i.e. non-retained issuances, issuances retained). Yet, for transparency reasons and for the sake of harmonisation, actual positions should be reported according to FINREP.
GBIC: No, we do not believe that these movements could occur too often.
GBIC: No answer.
GBIC: The “Template Related Instructions” lack explicit detailed references to FINREP data points in the format “Form.Colum.Row” and differentiation according to whether reports are for IFRS or nGAAP users. The previously shown references to FINREP tables, rows, and columns are not included any longer. Quoting references to FINREP definitions (Annex V) without including the relevant FINREP tables hampers efficiency and user friendliness – which were supposed to be the main reason for this harmonisation exercise.
GBIC: For banks applying IFRS for accounting purposes, in general, yes – if concrete references to FINREP tables, rows, and columns are included. For banks applying n-GAAP, kindly see our general remarks on EBA’s efforts to harmonise funding plan reporting.

In addition to that, other instructions lack accuracy. For example:
Assets (P01.01), Row 010: the heading says: “Cash and cash balances at central banks”, whereas the instruction refers solely to the definition of cash balances at central banks. It is not clear what the report is requesting in the designated cell. Only cash balances at central banks? Including cash balances? And what about other demand deposits that are included in FINREP reporting? Will they need to be considered as well?
GBIC: We believe that 28 February as a reporting date is too early and does not provide reporting banks with sufficient time. Please bear in mind that within the first two months of a year banks prepare their financial statements and for auditing of these. In addition to that, banks will also finalise and publish their disclosure reports within a given period. Consequently, as an alternative reporting date we advocate 31 March.

Please note that a proper alignment with FINREP is only possible with exact FINREP references to FINREP data points in the format “Form.Colum.Row” and differentiation according to whether reports are for IFRS or nGAAP users.
Sven Schoenborn
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