Stellungnahme DK zu EBA Draft ITS "On Asset Encumbrance Reporting under article 95a of the draft Capital Requirements Regulation (CRR)"
The basis for the CP/2013/05 is the requirement of Article 95a CRR as well as the publication of ESRB 2012/2 of 20 December 2012. While the CRR requires that institutions report, at least in a summarized form, the volume of their repurchase agreements, securities lending and all forms of encumbrance of assets, the ESRB recommendation contains details of the data which are to be covered by a guideline yet to be adopted by the EBA (now, instead of this guideline, an ITS is being introduced due to the CRR requirement).
The ESRB publication Foresees a phase in period for reporting obligations. According to this, the information reported should include a breakdown by asset type and should be provided on an annual basis. Based on the experience gained until 31 December 2014, the requirements should be extended to include the disclosure of asset quality and semi-annual reporting in as far as the EBA believes that this will provide reliable and meaningful information.
The Consultation Paper now published by the EBA goes far beyond the requirements which the ESRB deems to be necessary in order to fulfil its macro-prudential oversight. Notably, there is no phase-in period foreseen, the reporting interval is at times extended to quarterly reporting, and the information to be reported includes far more data than "asset class" and "asset quality".
We advocate that the new reporting obligation only apply to CRR institutes with a balance sheet total of more than €30bn (30 billion) and that this be implemented gradually in analogy to the requirements of the ESRB and only in as far as the expansion of the reporting obligations can be proven to supply reliable and meaningful Information. For this purpose, we propose that for the year 2014 reporting be initially on an annual basis for Part A (encumbrance overview) and Part D (covered bonds). In order to provide banks with sufficient time to take the necessary technical steps to implement the new requirements, reporting should not begin before Q3/2014. Any expansion to semi-annual reporting with additional requirements could be implemented in 2015 following evaluation of the results by the EBA. […]