Response to consultation on XBRL Taxonomy (v2.1) related to remittance of supervisory data

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Taxonomy file version tags: Respondents’ views are sought on the relative value of each approach, or any reasonable alternative.

N/A

General comments:

For columns 410-480 from C.06.00 table, where “capital buffers” are reported, COREP 2.1 taxonomy has created the following metric:
Eba_mi212: Risk weighted exposure

There is no background in the ITS or in the Directive 2013/36/EU for saying that these columns should show the risk weighted exposure related to the different buffers. Instead of it, ITS talks about “buffer requirements”

Clarifying this point, would avoid misunderstandings.

Using “risk weighted exposure” as the name of the metric could lead to misunderstandings, so it would be advisable to assign a more adequate metric, or to create one “ad hoc” for these buffers.

Changes would affect both versions of taxonomy (Table C.06.00, columns 410-480)

Name of organisation

Banco de España