EBA欧洲银行-Public-hearing-on-review-of-ITS-on-reporting-for-resolution-plans-261117_24页_2mb

报告摘要

EBA Resolution Reporting Review Summary

Core Content

The European Banking Authority (EBA) conducted a review of the Implementing Technical Standards (ITS) on reporting for resolution plans in 2017. The review aimed to improve the consistency, quality, and efficiency of data collection and reporting across the European Union, aligning with the Bank Recovery and Resolution Directive (BRRD). The EBA identified the need for updating the existing ITS, which were developed in 2012-2014, due to limited initial experience in resolution planning and the resulting inconsistencies in data collection practices.

Main Viewpoints

Reasons for the Review

Outdated Standards: The original ITS were based on limited experience and did not reflect current best practices in resolution planning.
Divergent Practices: Different authorities collected varying levels of information, leading to duplication and inconsistency.
Lack of Data Point Model: Without a standardized data model, data quality and consistency were compromised.
Limited Automation Tools: Authorities lacked the tools for automated data collection, quality control, and exchange.
Inconsistent Information Exchange: The lack of a unified data model led to inconsistent information sharing between authorities and the EBA.

Approach Envisaged

Clarify Scope: Define what data must be collected from institutions.
Format and Procedural Requirements:
- Develop a Data Point Model (DPM) with taxonomies and validation rules.
- Establish minimum prescriptions on the scope, level, and frequency of reporting.
Content Requirements:
- Ensure data items are collected as defined.
- Review and update individual templates to reflect recent resolution planning experience.

Key Information

Reporting Levels

Union Parent Undertaking Level: All information must be transmitted for the entire group.
- Includes organisational structure, critical functions, and core business lines.
Prudential Group or Resolution Group Level: Consolidated liabilities and own funds requirements.
Entity Level (Solo): Financial information at the point of entry, MREL-related liabilities, and deposit insurance data.

Format Requirements

The EBA proposed the use of XBRL (eXtensible Business Reporting Language) for structured data transmission.
The DPM will provide a structured representation of data items, including technical specifications and validation rules.
Templates will be based on the existing supervisory dictionary, ensuring consistency in data definitions and quality.

Main Changes in Templates

Organisational Structure Template:
- Merged governance and management with organisational structure.
- Removed sections on authorities and legal impact.
Liabilities Structure Template:
- Revamped to clearly identify excluded liabilities, bail-inable liabilities, and MREL-eligible liabilities.
Intragroup Financial Connections Template:
- More granular counterparty-by-counterparty data.
Critical Functions Template:
- Introduced a new "criticality assessment" template for documenting the identification of critical functions.
- Added a "critical services" template for reporting services essential for critical functions.
FMI and Information Systems Templates:
- Streamlined to include only those FMI and information systems indispensable for the provision of critical functions.

Questions for Consultation

The EBA invited comments on the following key questions:

Are the proposed remittance dates appropriate?
Is the technical feasibility of each block of templates acceptable?
What transition period is needed for FMI and information systems reporting?
Are the nomenclatures for FMI services, enabling services, and information systems suitable?
Is the proposed framework suitable for investment firms?