EBF: EBA consultation on guidelines on ICAAP and ILAAP information

11 March 2016

The EBF welcomes EBA's consultation paper, saying that having detailed guidance on the required content of an ILAAP and ICAAP is vital to ensuring the consistency and comparability of ILAAPs and ICAAPs, because it allows supervisors to consistently assess their reliability.

Furthermore, European Banking Federation (EBF) welcomes the fact that the EBA draft guidelines on ICAAP and ILAAP information collected for SREP purposes recognise that the ICAAP and ILAAP are internal processes. EBF would like to emphasise the need to maintain the ability for banks to have a flexible approach to their capital planning.

Among others, EBF highlights these key messages:

• EBA should limit the amount of information requested to elements that are actually relevant and manageable for an ICAAP/ILAAP.
• The ICAAP/ILAAP information obtained for SREP purposes shall not control the format of the ICAAP/ILAAP.
• It is often unclear whether the information specified is requested or suggested.
• The Guidelines should endeavour to provide clear justifications for specific documentation to be provided as part of ICAAPs/ILAAPs.
• EBF has some concerns about the reader’s manual that should provide “an overview of where the information items specified in these guidelines can be found in the documentation provided by an institution” and that should follow the same structure established in these guidelines.
• The proposed order of contents of the ILAAP could be simplified and alternately structured in such a way as to allow firms to more clearly demonstrate their liquidity adequacy.

Full response

© EBF