20 March 2014

EBF response to EBA draft Guidelines proposing harmonised definitions and templates for funding plans of credit institutions

In principle the EBF agrees that funding plans are important for each bank, and a standard report across the EU makes sense in order to assess the feasibility of funding structures across the financial sector.

However, EBF expresses concern that the EBA should treat its consolidated, EU-wide funding plan with care because:

• forecasts are based on assumptions which will never be totally accurate in their predictiveability and when consolidating the funding plans from all EU banks such variances inforecasts will be magnified.
• because banks undertake their funding plans at different points throughout the year, thedata that they receive might already be 6 months old and therefore subject to review bythe banks.
• is there merit in consolidating all EU countries into one funding plan (especially Eurozoneversus non-Eurozone)?

In a first brief analysis EBF founds some information missing or not detailed enough, other information requested EBF considers not indispensable for fulfilling the mandate of the ESRB recommendation. The additional technical and organizational efforts for banks to be undertaken for complying with the CP will be material therefore the template request should be restricted to the minimum necessary for covering the original ESRB intention.

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