EBA欧洲银行-BSG-response-to-Consultation-Paper-28EBA-CP-2015-232908-March-2016_7页_223kb

EBA Banking Stakeholder Group Summary on Draft Implementing Technical Standards for FINREP under IFRS 9

Core Content

The EBA Banking Stakeholder Group (BSG) has provided feedback on the Draft Implementing Technical Standards for the FINREP (Financial Reporting) templates, which aim to align supervisory reporting with the new IFRS 9 standards. These standards replace the previous IAS 39 and introduce significant changes in the classification, measurement, and impairment of financial instruments. The BSG’s comments focus on ensuring that the new reporting requirements are clear, consistent, and practical for financial institutions to implement.

Main Views and Key Information

1. General Comments on IFRS 9 Changes

• The new IFRS 9 classification and measurement rules simplify the recognition of financial instruments but introduce more complexity in impairment measurement through the expected loss model.
• The hedging accounting rules under IFRS 9 offer potential improvements in the use of fair value and cash flow hedges by relaxing the conditions for qualifying hedging relationships.
• The BSG supports the anticipation of new templates and rules in FINREP to align with IFRS 9, as this will facilitate the transition of banks' information and accounting systems.

2. Replies to Specific Questions

Q1: IFRS 9 Classification and Measurement in FINREP Templates

• Answer: The BSG believes that all relevant changes from IFRS 9 have been adequately reflected in the templates.

Q2: Impairment Reporting for Assets Measured at FVOCI

• Answer: The BSG confirms that the split between fair value changes due to credit risk and other causes is consistent with IFRS 9 and the mandatory disclosures, and thus the templates are appropriate.

Q3: Derecognition Criteria for Written-off Amounts

• Answer: The BSG suggests that the current criteria for derecognition are too general and could lead to inconsistent application across institutions. A more detailed definition is needed.

Q4: IFRS 9 vs. IAS 37 for Off-Balance Commitments

• Answer: The BSG agrees that some items in Annex I of Regulation (EU) 575/2013 may still be measured under IAS 37, as they may not qualify as financial instruments under IFRS 9.

Q5–Q7: Loan Commitments, Guarantees, and Open Retail Portfolios

• Answer: These questions are not applicable to the BSG, as they do not represent a financial institution.

Q8: Reporting of Transfers Between Impairment Stages

• Answer: The BSG finds the instructions and template for transfers between impairment stages to be sufficiently clear.

Q9: Net Basis Reporting for FVOCI Impairment

• Answer: The BSG supports the net basis reporting of impairment on assets measured at fair value through other comprehensive income (FVOCI), as it aligns with IFRS 9.

Q10–Q13: Impairment and Hedging Reporting

• Answer: The BSG believes that the current templates and instructions for impairment and hedging reporting are adequate and consistent with supervisory needs. They do not require further changes.

Q14: Reporting of Expected Reclassification Timing

• Answer: The BSG considers the maturity breakdown in template F11.5 to be sufficient for supervisory understanding and does not advocate for alternative reporting formats.

Q15–Q17: Valuation and Cost of Reporting

• Answer: These questions are not applicable to the BSG. However, they note that the current reporting requirements are less costly than the proposed changes.

Q18–Q19: Structure and Content of Templates

• Answer: The BSG generally agrees with the structure and content of the proposed templates and the amendments to Annex III of Regulation (EU) No 680/2014. They find the instructions clear and do not require specific clarifications.

Q20: Clarity of Instructions

• Answer: The BSG finds the instructions clear and does not identify specific areas needing clarification.

Q21: Additional Costs from Revised FINREP

• Answer: The BSG believes that the proposed changes do not introduce additional costs beyond those required for implementing IFRS 9 and IFRS 7. They align with the accounting changes and do not significantly increase reporting burdens.

Conclusion

The BSG supports the alignment of FINREP templates with IFRS 9 and believes that the proposed changes are necessary and practical. They emphasize the importance of clarity and consistency in reporting and suggest minor refinements where needed, particularly in derecognition criteria and data reconciliation. Overall, the BSG views the implementation of IFRS 9 in supervisory reporting as beneficial and well-prepared.