We welcome the EBA efforts to promote an active participation of the industry in developing such pivotal projects like the Pillar 3 Data Hub (P3DH). The EACB recommends a number of adjustments that would streamline process and implementation efforts. We exhort the EBA to reassess the expectations and withdraw the request to including accompanying narrative with the quantitative data. Regarding the collection of contact points information, the template “X 00.01 - P3DH” (if this option is chosen) should only need to be reported in the event of an update to the contact persons and not on a monthly basis. We have also proposed possible improvement regarding data submission and the establishment of a test environment.
We would also like to stress that the feedback presented below remains partial given that substantial elements and further obligations are yet to be defined, in particular regarding the requirements for SNCIs that will be addressed at a later stage.