EBF comments on the EBA consultation paper on draft ITS on disclosure for own funds by institutions

31 July 2012

The EBF supports the consultation paper's overall thrust toward the development of comprehensive, transparent disclosures which meet the needs of market participants. It has, however, strong reservations over the approach proposed to meet this objective.

The EBF supports the consultation paper’s overall thrust toward the development of comprehensive, transparent disclosures which meet the needs of market participants. It has, however, strong reservations over the approach proposed to meet this objective and, moreover, on the process.

EBF highlighted these key points:

• The objective of achieving enhanced transparency is supported.
• The proposed templates need to be brought in line with the expectations expressed by the users’ community.
• EU Authorities should increase their efforts to convince international institutions to adopt an integrated approach to reporting requirements on a global level.
• Disclosures regarding significant subsidiaries should be required in exceptional circumstances only.
• The consultation on the proposed common templates did not duly observe Better Regulation Principles.
• The common templates should aim to achieve a minimum level of standardisation to satisfy the expectation of consistency, with flexibility allowed at institutional level to promote an enhanced disclosure with quality narratives to assist users in making informed decisions.
• The Capital Requirements Regulation, as proposed by the European Commission, does not provide the EBA with a legal mandate to prepare technical standards to impose disclosures requiring an accounting/prudential reconciliation of the whole balance sheet nor to impose templates which institutions are required to use when disclosing their capital situation during the transition phase.

Full response

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