Response to consultation on draft Implementing Technical Standards on Pillar 3 data hub
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.
As we understand it, explanations of the templates should be part of the explanations in the PDF report. At the very least, it should be permissible to retain the location in the PDF report. However, at the EBA's public hear-ing on 21 October 2024, it was reiterated that the accompanying narrative for the individual quantitative forms should also be included in the XBRL-CSV files. We continue to believe that this form of double mapping should be avoided in general to prevent additional manual effort. The contents are also included in the overall PDF report.
However, should explanations be required in the XBRL-CSV templates, we request that the solution be as simple as possible, for example in the form of a text field. The number of characters allowed should not be limited, and the use of multiple text fields should be allowed. Regardless of this, the technical specifications for this would not be published until DPM 4.1. The requirement to include comments in the XBRL-CSV files is new and was only defined as part of the ongoing consultation. It would be difficult to implement the technical aspects and set up the necessary delivery routes for this within about three months. We therefore suggest that the requirement ‘including accompanying narrative’ be dropped.
Furthermore, according to the EBA at the public hearing on 21 October 2024, the DPM 4.1 relevant for the P3DH will not be published until Q1 2025 or perhaps even Q2 2025. In our view, this is much too late and jeopardises timely and high-quality implementation of the DPM by software providers and institutions. We therefore request that the P3DH section in DPM 4.1 be published in Q4-2024.
At the EBA's public hearing on 21 October 2024, the EBA announced the establishment of a test environment for the P3DH, but only for the imple-mentation phase. For the submission of Pillar 1 reports, the NCAs and the ECB (CA) offer the technical possibility of making test submissions in a test environment. We therefore ask the EBA to provide a permanent test environment so that test submissions can be made at any time. We believe that this would significantly improve the submission process.
Furthermore, point 50 states that national languages may be used for the explanations. It should therefore be technically ensured that all characters deviating from the English alphabet are accepted and not changed during transmission or publication.
In addition, we would like clarification as to whether it is sufficient to up-load the disclosure report as an unprotected PDF document to P3DH for the transmission of the PDF file.
Question 2: Would you agree with the specification to provide the information on remuneration policies separately? If not, please explain the reasons why.
Yes, we are in favour of submitting remuneration information in accord-ance with Article 450 of the CRR in the form of separate files.
Practice shows that by the time the general disclosure report is submitted, the internal bonus and profit-sharing rounds required to prepare the re-muneration report have rarely been completed. In view of this, CRR 3 in-troduced the option of submitting the remuneration information at a later date. In addition, remuneration issues are often the responsibility of differ-ent people from those responsible for disclosure. At least the option of separate submission should therefore be granted.
Question 3: Would you agree with the proposal on the collection of contact points information, including the suggested monthly frequency?
The monthly frequency seems too bureaucratic, since if one point of con-tact leaves, nominating two people should generally ensure that at least one point of contact can be reached. In addition, providing a functional e-mail address ensures that contact can be made in the event of a change of personnel. Assuming that this procedure is also to be applied to small and non-complex institutions (SNCIs), which are only required to disclose the necessary data annually, a monthly frequency would result in unnecessary additional administrative work, particularly for SNCIs. We therefore sug-gest that notification be made when the point of contact changes.
Question 4: Would you have any comments or suggestions on the most adequate profile of the contact persons within the institution?
The profile should be decided internally on an institution-specific basis. A uniform requirement by the supervisory authority seems unnecessary. In our view, there is therefore no need to define a profile for the contact per-sons. On the one hand, this is not a requirement under the CRR, and on the other hand, the institutions will only appoint suitable persons in their own interest in order to ensure an efficient process. Therefore, the addi-tional administrative burden should be avoided.
If criteria are nevertheless prescribed or recommended, it would be advan-tageous for practical relevance if they were persons who are also closely involved in the operational implementation and publication of the disclosure. We would take a rather critical view of the appointment of man-agers (B-, C-level) due to their task profile and frequent scheduling in their daily workload.
For example, the institutions could decide to appoint two contact persons (primary and secondary) from the department responsible for disclosure and two contact persons (primary and secondary) from the department responsible for XBRL submission – should these differ – so that availability is guaranteed at all times.