A number of concerns were raised. Some respondents believe the guidelines are too detailed and increase the already significantly large amount of disclosures. Clarity is required on what is to be considered a situation of “stress”.
As regards general comments received, Ms Beaudemoulin noted that most respondents are supportive of CEBS’s endeavours to help financial institutions improve their risk disclosures. In particular, respondents welcome the use of high-level principles / good practice disclosure and the fact that the principles are not compulsory.
However, there were also a number of additional comments :
· There are concerns that the guidelines are too detailed and increase the already significantly large amount of disclosures;
· Also there is a perceived need to clarify:
o how the guidelines interact with other disclosure requirements;
o the scope and objective of the guidelines and what is considered a situation of “stress”.
Most of these concerns were shared by participants. CEBS representatives noted that it will aim to address these points by clarifying the scope of the principles and, in that context, what is considered to be a “stressed” activity. Moreover, the principles should not add or get in the way of existing requirements.
It was questioned whether some of the principles (e.g. principles 1, 4 and 6) do not go beyond what is requested in existing disclosure requirements and thus go against one of the underlying premises of the CP.
One participant noted that most principles are already present in some form or another in other disclosure requirements. Ms. Beaudemoulin said that these principles are deemed to be particularly important and conducive to achieving high-quality disclosures. She therefore deems it important to highlight these principles in a free-standing document.
© CEBS - Committee of European Banking Supervisors
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