Stellungnahme DK zu Implementing Technical Standard on Supervisory Reporting (COREP and FINREP)

11. Dezember 2013

On 30 October 2013, the EBA submitted to the EU Commission its draft Implementing Technical Standard (ITS) on reporting for asset encumbrance. The first-time reporting deadline scheduled for banks with a balance sheet total exceeding EUR 30 billion envisaged thereunder is 30 June 2014.

At present, banks are working extensively on the implementation of a host of new reporting requirements. During this exercise implementation of the future requirements under the Capital Requirements Regulation (CRR) will probably constitute the largest challenge. In addition to this, at present banks need to simultaneously cope with a range of supervisory data requests. Inter alia, this also involves a supervisory risk assessment which is being conducted by the European Central Bank as part of its comprehensive assessment. Essentially, all data requests will have to be processed by the same experts.

As a result, at present, the resources for implementing any further reporting requirements within banks are exhausted. Hence, we would very much appreciate a postponement of the first reporting reference date to 31 December 2014 also for banks featuring total assets exceeding the EUR 30 billion threshold. […]

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