In its current version, the level of detail of the information required for the green asset ratio is very high.
Moreover, GBIC considers the duplicate disclosure of templates in two external reports by the institutions to be superfluous (templates 8 and 9 according to the EBA Pillar 3 ITS and templates 1 and 3 under the COM draft of the delegated act on Article 8 of the Taxonomy Regulation).
Questions for consultation
Question 1: Are the instructions, tables and templates clear to the respondents?
With regard to risk management, we consider the requirements, tables and underlying templates to be suitable to a limited extent for meeting the requirements of Article 435 of the CRR in conjunction with Article 449a of the CRR. Providing the information would trigger enormous costs, and they do not reflect the different ways in which the business models of significant institutions are affected by ESG risks. In the case of the intended granular scope, there are fears that any information overload will not provide the addressees or market participants with the necessary insights for capital market decisions in line with the original objective of the disclosure. This is the case in particular because of the fears of inconsistencies with various comparable requirements by other standard-setters (e.g. disclosure on the basis of the Taxonomy Regulation, the Disclosure Regulation concerning investment advice, as well as the non-financial statement), all of which are still under development....
More from The German Banking Industry Committee (GBIC)
BDB
The German Banking Industry Committee is the joint committee
operated by the central associations of the German banking industry.
These associations are the Bundesverband der Deutschen Volksbanken
und Raiffeisenbanken (BVR), for the cooperative banks, the
Bundesverband deutscher Banken (BdB), for the private commercial
banks, the Bundesverband Öffentlicher Banken Deutschlands (VÖB),
for the public-sector banks, the Deutscher Sparkassen- und Giroverband
(DSGV), for the savings banks finance group, and the Verband deutscher
Pfandbriefbanken (vdp), for the Pfandbrief banks. Collectively, they
represent more than 1,700 banks.
© BDB - Bundesverband Deutscher Banken
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