EBF comments on the consultation on guidelines on disclosure requirements under part eight of the regulation
Publication date: 15 September 2016
The draft Guidelines fail short of achieving their outspoken objective and the EBA initiative lacks, moreover, any legal basis. The document should be presented as a mere (non-binding) opinion of the European Banking Authority.
The level of granularity of the proposed templates is overwhelming whilst a careful detailed cost-benefit analysis is lacking. To meet EU Better Regulation Principles, the EBA may be expected to carefully explain on a template-by-template basis how the excessive detail of the disclosures would be contributing to market discipline.
The suggested early implementation date of a subset of 11 templates by year end 2016 is not feasible.
With regards to the details of the proposals, definitions are unclear in many cases and various templates would benefit from a review as well.
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