ESBG sent a letter to the European Central Bank (ECB) Supervisory Methodology Division regarding the draft Short-Term Exercise (STE) package for the Supervisory Review and Evaluation Process (SREP) 2024 data collection. 

This initiative was developed as a follow-up to a longer and more detailed ESBG paper already submitted to the ECB on 20 October on the same topic. The paper provided general considerations and suggestions on the draft package, thus highlighting specific issues with the design and timeline of specific templates.

ESBG stressed that the proposed changes significantly increase the operational burden associated with the STE reporting for banks. In particular, the new proposed templates represent a formidable increase in data-gathering requirements which comes in addition to the already significantly expanded reporting obligations outside of the SREP. Moreover, the regulatory reporting framework for both interest rate risk and market risk already goes beyond the scope and requirements of the existing STE templates, thus making the information in the latter redundant.

Considering the material expansion in both the scope and volume of required data, the implementation timeline is too short. In light of the methodological challenges posed by some of the new reporting requirements, as mentioned above, we suggested considering a larger period between the date of presentation of the package and the date of implementation to give appropriate time for operationalisation.

The STE package is currently going through the internal ECB decision-making process and the templates shall published on the ECB website in the second half of November.