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14 April 2015

EBF response to EBA consultation paper on draft ITS on procedures, forms and templates for the provision of information for resolution plans

EBF acknowledges that the resolution authority will have flexibility to adapt the scope and the level of detail required. However, it is worth emphasising the need to clarify the scope of subsidiaries outside the EU required to report information.

In particular, information from the subsidiaries of a multiple point of entry group located in third countries, which are themselves a resolution subgroup, should not be required to be included in the templates.

Moreover, while Article 11 of the BRRD empowers the resolution authority to request all the necessary information from institutions, greater cooperation and information-sharing between the resolution authority and the competent authority would be welcomed. This will avoid the duplication of information requests for institutions and therefore reduce their workload regarding information reporting.

The  proportionality  principle  should  be  taken  into  account  as  the  amount  of  information required  is  exhaustive  and inappropriate  for smaller and  less  interconnected  institutions.

Particularly, the granularity of the information required is a concern in several templates. On the one hand, European banks, especially global ones, may comprise a very large number of legal entities, many of them neither material nor connected with critical functions. Requiring information for those entities within the group could be an excessive burden and does not provide any value for resolution purposes.

In order to avoid reporting burden and ensure that the information requested is really necessary for resolution planning purposes, the EBA should define quantitative thresholds and materiality criteria to define the scope more precisely.

The EBF is also concerned that banks will have to build and maintain the data according to EBA templates “just in case” even though most of the data could be derived from supervisory sources.

EBF  understands  that  the  EBA  is  trying  to  avoid  duplication  by  inviting  competent authorities  to  cooperate  with  resolution  authorities,  however  the  draft  templates  contain requests for information already available from supervisors . Instead of proposing the current set of templates EBA should come up with a set of templates “not available from any other source”.

The  amount  of  information  currently  proposed  will  require significant IT  support  in  order  to ensure that the data is accurately updated and reflects the actual organisational structure.

The maintenance of this information, both at the authorities as well as in the institutions will lead to substantial work both in terms of IT development, IT resources and administrative resources.

Full response


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