Technical Standards on supervisory reporting XBRL UK 17 June 2013| London Meri Rimmanen| EBA Wolfgang Strohbach| EBA © 2013 | EBA | European Banking Authority Outline > Financial supervision in the EU – role of the EBA > Single rulebook and the case for harmonised supervisory data > Technical standards on supervisory reporting – main features > Facilitating implementation of supervisory reporting requirements 2 European System of Financial Supervision EU central banks EU supervisors Joint Committee ESRB ESFS EIOPA EBA ESMA Macro prudential Micro prudential 3 EBA regulatory tasks Common rulebook Maximum harmonisation ...but proportionate to different financial institutions EU Co-Legislators Sectoral Directives EBA ‘Implementing legislation’ EBA role: provide advice EBA issuing guidelines and recommendations (as before) Developing draft binding technical standards 4 Outline > Financial supervision in the EU – role of the EBA > Single rulebook and the case for harmonised supervisory data > Technical standards on supervisory reporting – main features > Facilitating implementation of supervisory reporting requirements 5 Technical Standards on supervisory reporting Objective: increase efficiency in reporting systems, enhance data analysis capabilities Reporting before… Group A Group B and after… Supervisor 1 Supervisor 2 Group C Supervisor 3 Different data definitions Several formats Different technologies Supervisor 1 Group A, B, C Common framework Supervisor 2 Supervisor 3 Common data definitions, instructions Single format IT standards 6 ITS on supervisory reporting - benefits Directly applicable > No implementation, or interpretation of the Regulation on national level ensures common definitions and instructions Technical translation of reporting requirements > Data point model and XBRL taxonomy > Common validation rules Truly harmonised supervisory data > Helps supervisors to assess asset quality, risk concentrations, liquidity positions, conduct peer analysis, analyse risk parameters across institutions > Harmonised definitions, especially on forbearance, non-performing loans and asset encumbrance significantly enhance identification of potential systemic risks 7 The role of EBA – main objectives and tasks Main objectives: Main tasks: Establishing EU single rule book Develop binding technical standards, guidelines, recommendations Promoting and enhancing quality and consistency of supervision Promoting common supervisory culture / supervisory practices Reinforcing oversight of cross-border groups Peer group analyses and peer reviews Monitoring effectiveness colleges Early warning of upcoming vulnerabilities EU-wide risk assessments and stress tests Risk dashboards Effective early intervention and bank resolution Reacting on risk warnings Handling of emergency situations 8 EBA oversight tasks – data usage Risk assessment Enhancing regular and ad hoc thematic risk assessments Stress testing Building common methodologies and conducting EU-wide stress tests (in cooperation with ESRB) Risk dashboard Building a system of key risk indicators (in cooperation with ESRB) Colleges Enhancing and supporting effective Functioning of colleges Crisis management Building capacity to handle emergency situations 9 Benefits of harmonised data >Data from banks across the EU provides a more comprehensive picture on exposures, risks, potential pockets of vulnerabilities >Peer analysis, identification of institutions posing systemic risk (outliers) >Provide high quality benchmarks for stress testing (harmonised definitions) and asset quality reviews >Improve analysis on concentration risk (large exposures, geographical breakdown of exposures) >Facilitate data sharing among competent authorities 10 Outline > Financial supervision in the EU – role of the EBA > Single rulebook and the case for harmonised supervisory data > Technical standards on supervisory reporting – – – – – – – Solvency Financial reporting Asset encumbrance Large Exposures Liquidity Leverage ratio Proportionality > Facilitating implementation of supervisory reporting requirements 11 ITS on supervisory reporting – what is covered EBA to deliver ITS in the following areas of the Capital Requirement Regulation (CRR): > Art 99 Solvency reporting, financial reporting > Art 100 Asset encumbrance > Art 101 Mortgage exposures reporting > Art 394 Large exposures reporting > Art 415 Liquidity ratios reporting > Art 430 Leverage ratio reporting Integrated approach to ITS development > Several ITS packaged as one EU Regulation which is directly applicable to all credit institutions and investment firms > Use of common structure/conventions/concepts/definitions 12 ITS on supervisory reporting – COREP Reporting population, level of application and scope of consolidation > Credit institutions and investment firms > Consolidated level and individual level > CRD scope of consolidation Frequency > Quarterly > Exception: semi-annually – Material operational risk losses (OPR Details) – Securitisation transactions (SEC Details) > Reporting delay 6 weeks Compliance monitoring > Monitoring compliance of capital requirements regulation > Granular information on risk parameters, risk concentrations, securitised exposures > Based on the CEBS reporting guidelines 13 ITS on supervisory reporting - FINREP Reporting population, level of application and scope of consolidation > IFRS institutions on a consolidated basis > National supervisory authorities may extend the implementation also to other institutions > CRD scope of consolidation Frequency > Quarterly, semi-annually and annually > Reporting delay 6 weeks Monitoring, IFRS-based reporting > Harmonised financial reporting following as much as possible IFRS > Some presentational options have been restricted in order to develop harmonised templates > In some cases the data requirements go beyond IFRS to provide data for risk assessment and analysis of systemic risks > Forbearance and non-performing loans reporting > Based on the CEBS reporting guidelines 14 ITS on supervisory reporting - Modules Asset encumbrance Quarterly Reporting delay 6 weeks Leverage Ratio Frequency Monthly/quarterly 2/6 weeks reporting delay CRD scope of consolidation Large Exposures Consolidated level and individual level Liquidity Credit institutions and investment firms Application Objective Monitoring and calibration EBA to report to the Commission Compliance monitoring Concentration risk monitoring Based on CEBS reporting Guidelines Monitoring and calibration EBA to report to the Commission Monitoring level of encumbered assets 15 Outline > Financial supervision in the EU – role of the EBA > Single rulebook and the case for harmonised supervisory data > Technical standards on supervisory reporting – main features > Facilitating implementation of supervisory reporting requirements 16 ITS on supervisory reporting - Data Point Model What is the DPM? > A data point is a data element required in the reporting framework, i.e. each template cell will correspond to a data point, and different cells with the same meaning should correspond to the same data point. > The DPM is a data model that captures the information requirements of the reporting framework. > The DPM is a dimensional model, meaning that each data point is categorised by a set of elements of different dimensions. Why the DPM? > Complex or dubious business concepts are broken down into more elementary concepts, in order to clarify the meaning of a data point. > The DPM expresses the reporting requirements at a logical level, without regard for any particular IT implementation. > The DPM bridges the gap between business and IT languages, providing a common ground of understanding. > The DPM will be the source for the generation of XBRL taxonomies. 17 ITS on supervisory reporting - Proportionality Reporting requirements shall be proportionate to the nature, scale and complexity of the activities of the institutions Proportionality included in different ways: >Size of an institution – Small institutions are exempted for some templates (asset encumbrance) >Non-significant activities/exposures/risk – Threshold for level of exposure/activity (Geographical breakdown, derivatives in leverage ratio) >Inherent proportionality – Templates reported only if a special approach/method is used or if institution has exposures (SEC, SEC details, IRB) >Reduced frequency – Templates where reduced frequency provides adequate data (Group structure, detailed and contingent asset encumbrance) 18 Facilitating implementation – Q&A mechanism Uniform interpretation of data requirements across EU > Detailed instructions included in the ITS Annexes > Q&A tool on EBA website (as of July 2013) > Public can post their questions via a web tool >EBA will –Review, categorise and prioritise questions –Publish all answers –Translate answers where necessary 19 Facilitating implementation – General timeline Dec 2011 • Public consultation on ITS (solvency, financial information and mortgage exposures) Feb 2012 • Public consultation on ITS (large exposures) June 2012 • Public consultation on ITS (liquidity and leverage) Sept 2012 • 1st interim release of ITS package Mar 2013 • 2nd interim release of ITS package July 2013 • Final ITS package (assuming CRR publication in OJ) Jan 2014 • ITS requirements apply (CRR application date: 1.1.2014) 20 Facilitating implementation – amendments of the ITS Currently under consultation >Asset encumbrance >Forbearance and Non-performing loans (FINREP) >Liquidity monitoring tools The ITS will be amended with these parts after the consultations Application dates will be later than 1 January 2014 21