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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.