Can a competent authority impose FINREP at a solo level. Moreover, would a competent authority be free to add to or delete information from a specific template?
According to the provisions of Article 99(2) of the Regulation (EU) no.575/2013, institutions subject to Article 4 of Regulation (EC) no.1606/2002 and credit institutions other than those referred to in Article 4 of that Regulation that prepare their consolidated accounts in conformity with the IFRS, shall also report financial information. In conformity with the Chapter 3 Section 2 of the future ITS, the financial information is to be reported on a consolidated basis. Till present, the National Bank of Romania exercised the option of extending the application of FINREP framework at solo level, by adapting the consolidated reporting framework FINREP issued by EBA (2005 and 2009 versions). By consequence, we are having now in force the reporting framework FINREP both at solo and consolidated level.
Article 99(2) to (4) of Regulation (EU) No 575/2013 (CRR) identify those institutions that have to report financial information in accordance with the
future ITS on reporting. Further, Article 99 of CRR lays down provisions for the application of FINREP on a consolidated basis.
A competent authority may therefore determine the content, frequency and reporting dates of FINREP by institutions at solo level.
*As of 1/8/2014 the content of this answer was modified to reflect the publication of the final ITS on supervisory reporting of institutions in the Official Journal of the European Union. As a result, the references to the ITS were updated and the disclaimer deleted. For reasons of transparency, revisions are highlighted in track changes.