The EACB welcomes the opportunity to comment on the EBA draft Guidelines on resubmission of historical data under the EBA reporting framework.
We notice that the consultation paper does not address the very relevant cost-benefit aspect. The approach proposed should be reviewed more accurately taking into account the cost-benefit for both the institutions and the supervisors.
We nevertheless support the aim of establishing uniform requirements for the submission of historical data. However, we see a fundamental question (especially for larger institutions) on whether the proposed tolerance limit is justified and operationally feasible.
More structural ways to ease the burden of the envisaged solution should be considered with a view to provide institutions with a framework that enables them to deal with resubmissions with manageable effort, and allows supervisory authorities to fulfil their mandate without being flooded with information that is not meaningful for banking supervision.
In this regard, it is important to determine a suitable materiality (or immateriality) threshold.
We also see a need to propose a reasonable solution to overcome the challenge to perform resubmissions under more than one DPM taxonomy or when an error in a datapoint effects multiple reports.
Finally, we see an evident need for a transition period: it would be difficult to manage both the arrival of CRR 3 and the related changes to the reporting framework, and the requirements of historical resubmissions.