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The rationale for amending the ITS was the need to clarify the level of consolidation and the approach to be taken when aggregating the data. The amended draft ITS move away from the host approach introduced in the former CEBS guidelines, and implicitly widely applied under the previous ITS. It follows, instead, a consolidated approach in line with the existing reporting framework with the aim of avoiding additional burden and to enhance the comparability of the data.
In addition, the aim of such a change is also to clarify the scope and the split of supervisory responsibilities to disclose information between the European Central Bank (ECB) and National Competent Authorities (NCAs) within the SSM as agreed in the Banking Union.
With regard to the disclosure of national options and discretions (O&Ds), for the first time, the amended ITS require Competent Authorities to disclose those O&Ds stemming from the Delegated Regulation on the Liquidity Coverage Ratio (LCR). In addition, the amendments provide more clarity on the differences between permanent and transitional O&Ds and between those O&Ds whose exercise has been entrusted to Competent Authorities and those, which are under the responsibility of Member States.