EBF acknowledges that the resolution authority will have flexibility to adapt the scope and the level of detail required. However, it is worth emphasising the need to clarify the scope of subsidiaries outside the EU required to report information.
In particular, information from the subsidiaries of a multiple point of entry group located in third countries, which are themselves a resolution subgroup, should not be required to be included in the templates.
Moreover, while Article 11 of the BRRD empowers the resolution authority to request all the necessary information from institutions, greater cooperation and information-sharing between the resolution authority and the competent authority would be welcomed. This will avoid the duplication of information requests for institutions and therefore reduce their workload regarding information reporting.
The proportionality principle should be taken into account as the amount of information required is exhaustive and inappropriate for smaller and less interconnected institutions.
Particularly, the granularity of the information required is a concern in several templates. On the one hand, European banks, especially global ones, may comprise a very large number of legal entities, many of them neither material nor connected with critical functions. Requiring information for those entities within the group could be an excessive burden and does not provide any value for resolution purposes.
In order to avoid reporting burden and ensure that the information requested is really necessary for resolution planning purposes, the EBA should define quantitative thresholds and materiality criteria to define the scope more precisely.
The EBF is also concerned that banks will have to build and maintain the data according to EBA templates “just in case” even though most of the data could be derived from supervisory sources.
EBF understands that the EBA is trying to avoid duplication by inviting competent authorities to cooperate with resolution authorities, however the draft templates contain requests for information already available from supervisors . Instead of proposing the current set of templates EBA should come up with a set of templates “not available from any other source”.
The amount of information currently proposed will require significant IT support in order to ensure that the data is accurately updated and reflects the actual organisational structure.
The maintenance of this information, both at the authorities as well as in the institutions will lead to substantial work both in terms of IT development, IT resources and administrative resources.
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