EBF LETTER – 27 MARCH 2020:
EBF assessment of reporting requirements in light of Covid-19
Ms Silke STAPEL-WEBER
Directorate General Statistics
European Central Bank
Mr Piers HABEN
Banking Markets, Innovation and Consumers
Euorpean Banking Authority
SUBJECT: EBF assessment of reporting requirements in light of Covid-19
Dear Ms Stapel-Weber,
Dear Mr Haben,
In the course of the global Covid-19 pandemic, its effects are been felt in every nation and every industry. While banks are taking all possible measures to weather the impact of the Covid-19 crisis, a close interaction with authorities is vital to be truly effective.
In a previous letter to the EU authorities, the EBF suggested various important proposals to neutralize the effects of the Covid-19 on the economy which was swiftly followed by very encouraging statements by the EBA and the ECB including references to the area of supervisory reporting and suggesting the possibility to have flexibility for non-critical supervisory measures and data requests.
It is in this context that we have performed an assessment of the banks’ reporting requirements identifying those where leeway in the remittance dates or implementation and completeness of the data submitted would be greatly welcomed by the industry since there is a risk that deadlines may not be met because of potential operational burdens during the coming weeks/months. On the one hand, some reports rely on a macro-economic scenario that under current circumstances both industry and authorities cannot accurately foresee, resulting in the most appropiate alternative to wait until the impact of the Covid-19 on the economy is properly measured. On the other hand, the massive teleworking efforts, never previously tested at this scale in a real situation, of the banks’ reporting teams imply some work absences due to the disease. The significant difficulties for the teams that are developing the new templates result in a slowdown of the project.
At present, it is not possible to predict whether firms will have problems submitting reports on time. Should this be the case, however, it would be very helpful if supervisors were to accept some minor delays and late submissions of reports and refrain from allowing them to have a negative effect on their standardised assessment of punctuality, completeness, and number of correction reports (DQ index for SREP).
Lastly, existing requirements should, in principle, be retained in their present form for the time being and no adjustments or new requirements should be introduced.