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The main legislative act to implement the single rulebook is the Capital Requirements Regulation (henceforth ‘CRR’) which sets out prudential requirements for institutions which are directly applicable as of 01.01.2014.In order to check institutions’pliance with these prudential requirements,petent authorities will make use of reporting requirements which were developed by the EBA and published as Implementing Technical Standards on supervisory reporting (henceforth ‘ITS’).These ITS are part of the single rulebook enhancing regulatory harmonisation in europe,with the particular aim of specifying uniform formats,frequencies,dates of reporting,definitions and the it solutions to be applied by credit institutions and investment firms in europe.Uniform reporting requirements are necessary to ensure fair nditions of petition between parable groups of credit institutions and investment firms and will lead to greater efficiency for institutions and greater nvergence of supervisory practices and allow supervisors to assess risks nsistently across the eu,thus enabling them to pare banks effectively and identify emerging systemic risks.
MAIN FEATURES OF THE ITS
Spe and level of application
The ITS set out reporting requirements relating to own funds and own funds requirements,financial information,losses stemming from lending llateralised by immovable property,large exposures,leverage ratio and liquidity ratios.As the its follow the spe and level of application set out in the CRR,they apply to credit institutions and investment firms on both (i)an individual and (ii)a nsolidated level,with the exception of financial information.Acrding to Article 99CRR, financial information included in the its is to be reported only on a nsolidated basis and only by those institutions that either apply International Acunting Standards (IAS)/International Financial Reporting Standards (IFRS)or are required by the respective petent authorities to apply IFRS for the purposes of calculating their capital requirements.
Proportionality,frequency and dates of reporting
As the its apply to all institutions subject to supervision under the CRR,reporting requirements have been developed taking into acunt the nature,scale and plexity of institutions’ activities.Proportionality is an integral part of the its,with certain reporting requirements being applicable only to institutions using plex approaches to measure their own funds requirements.A significant number of data points do not have to be reported by all institutions but only by those institutions which have significant risk exposures or significant activities.Quantitative criteria ensure a uniform application and are calibrated on the basis of information provided by petent authorities,with the aim of exempting institutions with insignificant activities or insignificant systemic importance.
The ITS set uniform frequencies on a template by template basis (a template represents a view of related data points) with a baseline quarterly reporting frequency,taking into acunt the nature and stability of the information as well as the plexity and administrative burden involved for institutions in llecting and reporting the information. The its also set uniform remittance dates (with a baseline of 30 business days for submission of quarterly reports) which ensure that reporting institutions submit information to petent authorities within a timeframe that represents a balance between timeliness and quality of reported data.This will allow institutions to better manage and schle their instance submissions in particular for institutions operating in many different jurisdictions.
Data Point Model
For the first time since the initial publication of CRD reporting requirements in 2005(so called REP),the EBA has also released a Data Point Model (henceforth ‘DPM’).The main objectives of developing a DPM are the following:
•Provide a detailed standard technical description of the data in order to ensure a mon interpretation,which in turn will help reporting entities when implementing new reporting requirements.
•By focusing on the logical structure of the information,and not on the structure and ntext of specific templates,the data points definitions bee independent of any particular views of data,providing the base ground for analytical exploration,and enabling future redesign of templates in a more homogenous and nsistent manner.
•Applying a logical and formal approach in describing data using monly known ncepts eases munication between business experts and it experts.
•It data exchange formats,and in particular XBRL taxonomies can be produced based on the DPM without depending on the knowledge and availability of business experts.
The approach chosen by the EBA was to define the DPM as a fully dimensional model.Thus the DPM describes each data point of the ITS reporting framework,by means of a specific and unique bination of members of different dimensions.Each data point rresponds to a cell of a template.each dimension is a category of information nsidered necessary to classify the data facts,and the members are the possible instances of the dimensions ([Prudential Portfolio].[Trading book]and [Type of Risk].[Credit risk]are examples of pairs [Dimension].[Member] used in the model).
The DPM also includes hierarchies of members,which are useful for understanding the breakdowns of data,and to define validations of summary data,across the parent-child structure of members.
Via the DPM metadata describing the ITS reporting templates,and the relation between template cells and data points,it is possible to know for each cell its dimensional categorisation,and to know for each data point its respective ordinates within the templates.
All the DPm metadata is stored in a repository available in ms Aess format,which is a database with a generic meta-model structure,designed to store DPMs for the current and any future reporting frameworks.This repository is being used as the base for the automatic generation of XBRL taxonomies,and can be explored in a variety of ways to understand the DPM ncepts and relations.
The meta-model is however not bound to any particular technology,and therefore XBRL specific nstraints,for example,are not reflected in the DPM if they would rce the clarity of the model. In order to streamline the process of automatic translation from the DPM to XBRL taxonomies,however,some additional model elements have been added,and a layer of XBRL properties (e.g.namespaces)will likely be extended to the database in future.
Other enhancements will follow to address additional issues,such as versioning of metadata.Both the templates and the data points’ categorisation are expected to change in the future,and keeping track of history of the unique data points is a fundamental requirement for data warehousing and time series analysis.
It solutions for data submission
The EBA has decided that the use of its XBRL taxonomies should not be mandatory for data submission from institutions to petent authorities.The main reason for this is that the its ver only a part of the whole data package an individual institution has to submit to petent authorities (other data requirements include statistical data,credit register data etc)and it is nsidered to be more beneficial,both by petent authorities and by reporting institutions,to maintain integrated reporting solutions as a unique national it solution for the whole data package.This will allow petent authorities to llect data as part of their existing broader reporting framework,provided that the specifications included in these its are met.
For data submission from petent authorities to the EBA,however,XBRL is likely to be the mandatory solution and hence the EBA will develop and maintain XBRL taxonomies that inrporate the requirements of the ITS.
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