Response to consultation on draft Implementing Technical Standards on Pillar 3 data hub
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Question 1: Do you agree with the proposed IT solutions that would support the implementation of the P3DH to Large and Other institutions? If not, please explain the reasons why.
We concur with the proposed IT solutions. We would appreciate if the quantitative part of the disclosure could be derived from already submitted supervisory reports, similar to the process for SNCIs.
Question 2: Would you agree with the specification to provide the information on remuneration policies separately? If not, please explain the reasons why.
We concur with the specification.
Question 3: Would you agree with the proposal on the collection of contact points information, including the suggested monthly frequency?
We generally agree with the proposed collection method. However, we believe that a monthly frequency is excessive and propose a quarterly submission as sufficient.
Question 4: Would you have any comments or suggestions on the most adequate profile of the contact persons within the institution?
The contact person should be someone involved in supervisory reporting and/or significantly contributing to the preparation of the Pillar 3 Disclosure report, such as by coordinating its creation.