Comments

Draft RTS CVA Risk of securities financing transactions (EBA/CP/2024/14)

Thomas Schlüter
Thomas Schlüter

The methodology of the new Business Indicator approach and the corresponding reporting template C16.02 (see EBA/CP/2024/07) require the computation of the business indicator and the preparation of the detailed reporting template C16.02 for each of the last three financial year-ends. 

The methodology of the new Business Indicator approach and the corresponding reporting template C16.02 (see EBA/CP/2024/07) require the computation of the business indicator and the preparation of the detailed reporting template C16.02 for each of the last three financial year-ends. 

We want to highlight that the first reporting dates will be burdensome, as for the first reporting date 31.3.2025 the figures for YE 2024, YE 2023 and YE 2022 must be (manually) processed in retrospect. This is challenging because FINREP reports might not be available in granularity (that is required for the preparation of the reporting form C16.02) or they are not available at all. In cases of deviations from the existing FinRep reporting (notably, concerning adjustments for M&A) the retroactive data provision will be very difficult.

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