EBF: EBA consultation paper on draft I.T.S. on supervisory reporting requirements for institutions (CP 50)

26 March 2012

The European Banking Federation supports the European Commission's intention to achieve a single rulebook and therefore strongly welcomes this Consultation Paper.

Key points:

• The industry fully supports the European Commission’s aim to achieve a single rulebook.
• It has grave concerns about the magnitude of the changes that are being proposed. It recommends organising a permanent dialogue with the industry.
• The proposed timing for the implementation of the proposal as well as the proposed remittance dates need to be reviewed.
• The proposals are flawed from a legal point of view to the extent that the Consultation Paper fails to explain why the information that it proposes to collect is needed, and also because the use that the Consultation Paper proposes to make of the principle of proportionality does not respect some basic principles of EU Law nor established jurisprudence of the European Supervisory Authorities.
• The FINREP requirements should be imposed only on institutions that prepare their consolidated financial statements on the basis of IFRS and should, moreover, be aligned to International Financial Reporting Standards (IFRS).
• The national discretions which the proposals seek to introduce need to be removed.
• The option whether to use XBRL for reporting purposes should rest with the firms and, therefore, not with their competent supervisor. A uniform solution should be elaborated in the area of electronic signatures.
• It would be advisable for the EBA to seek assistance from an external consultant to make an assessment of the precise impact of the various building blocks of the proposed framework.

Full consultation paper

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