The EACB welcomes the opportunity to comment on the EBA DP on a Feasibility Study of an Integrated Reporting System under Article 430c CRR.
- While one of the desirable objectives of an integrated reporting system would be to reduce the number and frequency of ad hoc requests, it should be considered that many such exercises arise from idiosyncratic reasons that are difficult to define upfront. There is therefore a risk that banks will have to face both a more granular system and persisting ad hoc requests, thus resulting in no relief from an administrative perspective. We see a need for a clear commitment from authorities to issue fewer ad hoc requests and invest more time in digging into the granular data that they would receive.
- As generally understood, proportionality in reporting is currently embedded via the templates. Such an approach would be hard to implement in a framework with increased granularity and fundamentally data driven. While discussions would still be needed on the most suitable way forward, we encourage EBA to continue give proportionality a prominent place in discussions.
- The timeline for implementation is a key cost driver, as also acknowledged by the EBA. We would reiterate that when the new dictionary is eventually set up, it must be flexible enough to be implemented by all banks and authorities, easy to update and adjust.
- Good governance arrangements will be key to the system, and it should not be overlooked that small institutions will have shoulder the bulk of costs at first. We believe that banks should be involved in the governance of the reporting system, even if not with “voting rights” at least with an advisory role.