Stellungnahme BdB an EBA und ESRB zur abermaligen Änderung der FINREP-Meldeanforderungen
On 15 March 2013, the EBA published an updated version of its templates, instructions, validation rules and data point model for implementing technical standards (ITS) on supervisory reporting.
In this version, all the previously dropped tables for geographical breakdowns of assets and off-balance sheet items have been reinstated. What is more, the templates now require a geographical breakdown of liabilities as well (tables 14.4 - 14.6). Given the
results of the prior consultation process, the banks have been considerably taken aback by the changes.
During the consultation on EBA's CP50, the geographical breakdowns were one of the banking industry's main points of criticism. The subsequent version of the templates published in August 2012 appeared to take this criticism on board. Banks have based their preparations for the new FINREP requirements on this version and on the information to emerge at the EBA's workshop on 13 September 2012. Technical implementation poses huge challenges even without the new complications since FINREP requires a combination of both accounting and risk management data. Banks have already invested considerable human and financial resources so that they will be in a position to deliver the requested information on schedule from Q1 2014. […]