November 28 2018

Comments on Draft Implementing Standards amending Implementing Regulation with regard to FINREP

We generally welcome the principle of proportionality in the additional reporting obligations for non-performing exposures (NPEs) which is reflected by the separation according to Module 1 and 2. That being said, we believe that it is possible to take the principle of proportionality even further into account within the scope of the FINREP reporting system. This could be done for example by generally excluding from Module 2 those institutions which, in accordance with Regulation (EU) 2015/534 of the European Central Bank on the reporting of supervisory financial information (ECB/2015/13), report on the basis of data points and/or oversimplified/simplified FINREP. It would be helpful if EBA could already work towards this goal in relation to the ECB.

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