EBF comments on the EBA Consultation on Data Point Model

19 June 2012

The European Banking Federation provided its preliminary comments on the Data Point Model. It includes observations that the European Banking Authority may wish to consider to improve the DPM proposals.

EBF's preliminary view is that the Data Point Model (DPM) is an excellent initiative. The Microsoft Access Database is an improvement as the documentation which it provides is structured and allows for a multitude of views on the same data and relationships.

At the same time, however, the DPM is a missed opportunity because the dimensionality is not implemented throughout the whole framework but only by table. Implementing dimensionality only by table is a good start. However, one would have expected dimensionality being defined on the whole Finrep and Corep Framework. Because this has not been done, duplicate data still needs to be delivered and validated to detect possible reconciliation issues. The EBA could have supported "one time data (element) delivery".

Obviously, a Consultation Period spanning 11 business days only is much too short to allow banks to examine in detail an entirely new IT-framework which consists of more than 20,000 table cells.

Whilst EBF understand the time constraints with which the EBA is faced, Authorities should also understand that banks cannot possibly be expected to adopt a piece-meal approach when revising their IT systems. It was also worrying to learn from the EBA's news communication of 7 June 2012 that a separate consultation on a DPM containing all the relevant technical specifications necessary for developing an IT reporting format will be published in the second half of 2012. This necessarily means that banks cannot possibly adapt their systems in a timely way to be ready to report for the first quarter of 2013.

The explanation provided in the consultation paper concerning the DPM is extremely limited.

• Even for banks’ IT experts the dimensional data model is difficult to understand in the absence of due explanations on its set-up and the design of the dimensions. Extensive documentation on the Methodology, Structure and Content of the Model (detailed definitions of Members, Categories and all other Data Elements used in the Model), as well as on the purpose and use of DP-codes, is a prerequiste for undertaking a close examination of the proposed model.
• Policy experts within banks have taken note of the explanation which is given in the consultation paper that institutions will be required to comply with the specifications included in the DPM. However, they have equally noted that the consultation paper does not make an effort to explain how the DPM will achieve this objective and, in particular, how banks that will not (be authorised to) report under XBRL will be expected to file their supervisory reporting in compliance with the DPM.
• The DPM is not consistent with the templates which the draft ITS on supervisory reporting had referred to. This has added to the confusion.

EBF would like to reiterate the comment it made when commenting on CP 50 and 51: It is absolutely essential that banks be allowed to report under the EBA XBRL taxonomy, even if the country of reporting is not publishing its own taxonomy.

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