EBA欧洲银行-CP06revised2_EBF_14页_149kb

报告摘要

EBF Comments on the CEBS Consultation on Amendments to Guidelines on FINREP

Core Content

The European Banking Federation (EBF) has provided detailed comments on the proposed amendments to the CEBS Guidelines on Financial Reporting (FINREP). The main focus is on the reporting burden, harmonization, alignment with IFRS, and implementation challenges for banks across the EU.

Main Views and Key Points

1. Reduction of Reporting Burden

The EBF supports any initiative that reduces reporting burdens, especially for cross-border banks.
They emphasize that the quantitative data reduction is welcome, but the increase in data requirements through new tables and cells may lead to a significant implementation effort.
The non-core information not aligned with IFRS is seen as unnecessary and may increase workload.
The business case for new data requirements is questioned, particularly for tables like the asset management schedule and interest income and expense schedule.

2. Uniformity of Financial Reporting

The EBF is concerned that the decentralization of reporting requirements to national authorities may hinder full harmonization.
They suggest that national discretions should be eliminated to achieve a uniform reporting framework across the EU.

3. Alignment with IFRS

The EBF believes that FINREP should align with IFRS and not diverge from it.
They recommend that references to IFRS should be maintained and that interpretation of IFRS should be the responsibility of IFRIC, not national regulators.
Some references to IAS 1.55 and IAS 1.85 in the tables are questioned, as they may lead to redundant disclosures.

4. Reporting Frequency and Deadlines

The EBF suggests that FINREP reporting should be semi-annual at most, to avoid unnecessary frequency.
They recommend that remittance dates for both solo and consolidated reporting should be aligned, with a 50 business day deadline from the end of the financial year.
CoreP and FINREP have different purposes, and thus should not share the same reporting frequency.

5. Versioning Policy

The EBF supports the versioning policy as it helps harmonization across Member States.
However, they note that more information is needed on the implementation process and how changes will be managed over time.

6. IT-Level Harmonization

The EBF supports CEBS's initiative to recommend IT best practices for cell definitions.
They emphasize the importance of XBRL taxonomy alignment with IFRS-GP to avoid duplication and improve data collection efficiency.

7. Cross-Border Reporting

The EBF advocates for cross-border groups to be allowed to report using the home country's tables for all subsidiaries.
This would reduce the reporting burden and improve consistency.

Key Recommendations

Delete unnecessary tables such as 25B, 25C, 25D, and 26 due to lack of business case and alignment with IFRS.
Simplify and align the reporting requirements with IFRS standards.
Clarify definitions and mapping between FINREP and IFRS, especially for terms like "retail" and "geographic breakdown".
Avoid mixing financial and risk reporting to prevent confusion and additional workload.
Ensure consistency in reporting frequency and deadlines across all levels (solo and consolidated).
Provide a contact point for banks during the implementation phase to discuss unclear cells or data requests.

Summary of Comments on Tables

Table	Comments
Table 3	Clarify notional amount definitions; remove "economic hedges" as it is not IFRS compliant.
Table 4	Remove "Debt securities" as it is not required by IFRS.
Table 5A	Change "incurred but not reported losses" to "collective impairment on collectively assessed financial assets".
Table 5B	Delete last column due to overlap with Table 4; justify new format with a business case.
Table 5C	Delete counterparty breakdown for equity instruments.
Table 5D	Clarify the definition of "domestic" in consolidated reporting.
Table 6	Clarify definitions of "retail" asset classes and "other secured loans".
Table 7	Simplify the table and delete detailed impairment movements.
Table 8	Refer to EBF comments on Table 3.
Table 10A	Clarify classification of regulated saving deposits; limit own credit risk to deposits and debt certificates.
Table 14	Need more guidance on categorizing fees and commissions.
Table 15A	Delete the table due to lack of internal use and high implementation costs.
Table 15B	Delete the table as banks only disclose net gains and losses.
Table 23	Question the need for quarterly reporting of consolidated entities.
Table 24	Delete the table as it does not contain accounting data.
Table 25A	Clarify the purpose of the table and the need for unrealized gains and losses.
Table 25B	Delete the table due to lack of business case.
Table 25C	Delete the table as the reason for inclusion is unclear.
Table 25D	Delete the table due to difficulty in identifying separable contracts.
Table 26	Delete the table due to lack of line-by-line data and differences between IFRS and CRD consolidation scopes.

Conclusion

The EBF highlights the need for harmonization, alignment with IFRS, and reduction of reporting burden. They suggest that some tables and data requirements should be removed or simplified, and that clear guidance and justification is necessary for any new data request. The EBF also supports semi-annual reporting, XBRL alignment, and cross-border reporting options to improve efficiency and consistency.

展开完整摘要