Response to consultation on draft Guidelines on the high earner data collection exercises under CRD and IFD

Go back

Q1: Are the sections on subject matter, scope, definitions and implementation appropriate and sufficiently clear?

The EBA’s draft guidelines do not envisage any special arrangements for dealing with negative reports. In Germany, section 9a(2) of the draft new Regulation Concerning Reports and the Submission of Documentation under the Banking Act (AnzV-E) envisages that non-significant institutions will continue to be exempt from regularly resubmitting negative reports. A clarification along similar lines should be included in the guidelines.

Q2: Are the sections on the scope of the data collection exercises sufficiently clear?

Name of the organization

On behalf of the German Banking Industry Committee, Association of German Banks

Organisation and governance

Legal and policy framework

Careers

Supervisory convergence

Direct supervision and oversight

Information for consumers

Ad hoc activities

Risk analysis

Reporting frameworks

Data

Publications

Media centre

Response to consultation on draft Guidelines on the high earner data collection exercises under CRD and IFD

Q1: Are the sections on subject matter, scope, definitions and implementation appropriate and sufficiently clear?

Q2: Are the sections on the scope of the data collection exercises sufficiently clear?

Name of the organization