Stellungnahme DK zur Überarbeitung der Baseler Offenlegungsvorschriften (Säule III)

10. Oktober 2014

In principle, we welcome the Basel Committee’s initiative to revise the Pillar 3 disclosure requirements and thereby to improve the provision of meaningful information for users of Pillar 3 reports. It also makes sense to require a more formal structure for certain disclosures and to standardise them since this will improve the comparability of information.

At the same time, however, we note that there has been a significant increase in the scale of information to be disclosed. We have serious concerns that the sheer abundance of information might overwhelm users, rather than helping them to obtain a better understanding of the risk exposures faced by individual institutions.

Our experience to date has shown that interest in Pillar 3 reports has tended to be low. This was shown clearly by the number of reports downloaded from the Internet as well as by the small number of queries received and by feedback from investors and analysts.

We have doubts as to whether the proposed disclosure requirements will meet their information needs. We are proposing in this case to proceed along the same lines as for the EDTF recommendations and to identify the information requirements in an interactive process involving the preparers and users of the reports. Ultimately, however, the package of requirements should only stipulate mandatory disclosure for information that is highly relevant for the majority of the users. Cost/benefit considerations should also be examined carefully at all times. […]

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