Response to consultation on ITS on Supervisory Reporting amendments with regards to FINREP
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Please also consider for excluding the tables F 18 and F 19 if these two table would be excluded from FINREP reporting and would be reportedto report them together with above mentioned tables.
Question 5 (on F 40.01, F 40.02) The information included in the two group structure templates is currently collected on an annual basis. Without prejudice to notification obligations under national laws, a more frequent collection (quarterly) would improve the timely reflection and awareness of changes to institutions’ group structures. Which benefits and challenges with regard to the compilation and reporting of this information on a more frequent basis do you envisage?
We do not see any additional benefits for quarterly reporting of tables F 40.01 and F 40.02 as Slovenian banks (and banks in general) do not have material changes in group structure on such a frequent level. Also these two tables are prepared manually, which means additional time and resources are required for preparation and control.Question 6 (on F 44.04, F 48.00) Some of the items included in templates F 44.04 and F 48.00 are also collected for the purposes of benchmarking in accordance with EBA’s Guideline on the remuneration benchmarking exercise (EBA/GL/2014/08). The items requested in FINREP are of high-level nature and full alignment has been sought to keep the reporting burden limited. What is your view on the inclusion of this information in FINREP? Do you see any inconsistencies between this data and the data collected in accordance with the GL on remuneration benchmarking exercise that impact the reporting burden?
Data for the tables F 44.04 and F 48.00 are not directly available in General ledger and also are not prepared or monitored in Accounting department. From this point of view and given the additional costs incurred we suggest that this table should be excluded from FINREP reporting.Question 7 (on several templates, see F 23.01 – F 23.03) The following templates (templates F 23, F 24, F 26, F 47) request information on loans and advances subject to definition of non-performing and forborne exposures (with the exception of loans and advances classified as held for sale), in contrast to F 18 and F 19 that cover ‘exposures’ in a broader sense, e.g. also debt securities. The rationale behind applying these additional templates to loans and advances only is that the majority of exposures in credit institutions’ balance sheets that turned non-performing are loans and advances. To have risk based focus to monitor evolution of asset quality and to balance reporting burden the templates focus on loans and advances only. Are the definitions and instructions on the definition of the scope clear?
Data reported in tables F 23, F 24, F 26 and F 47 include data regarding non-performing, forborne exposures and collateral. These data are not available in General ledger and are also are not prepared or monitored by Accounting department. Usually these data is are prepared and reported in Risk department. Also we would like to point out that in these tables will be reported detailed information will be reported which is highly granular and not all available automatically, so additional manual inputs will be necessary and thus additional costs will incur. For these reasons and taking into consideration the lack of added value we suggest that these tables should be excluded from FINREP reporting.Please also consider for excluding the tables F 18 and F 19 if these two table would be excluded from FINREP reporting and would be reportedto report them together with above mentioned tables.