Reporting requirements related to resolution
The Financial Stability Authority regularly collects information from the credit institutions and investment firms under its remit for the purpose of drafting resolution plans as well as setting and monitoring MREL (Minimum Requirement for Own Funds and Eligible Liabilities).
Resolution reporting is comprehensive in scope, including information on the institutions’ debt structure, requirements for own funds, the assessment of the criticality of their operations, participation in financial market infrastructure and the key information systems used. Reporting based on standard forms and templates constitutes the foundation for the information needs associated with resolution planning but, in addition, the Authority can issue separate information requests on an institution-specific basis or generally for all institutions with regard to the annually determined focus areas of planning efforts.
The Financial Stability Authority collects reporting information for planning purposes, as a rule, either annually or in two-year intervals depending on whether the use of resolution powers has been deemed to be necessary if the institution in question experiences a crisis. Information pertaining to the monitoring of the MREL requirement is, as a rule, collected quarterly to enable effective monitoring.
The Financial Stability Authority also works closely together with the Financial Supervisory Authority with regard to reporting. The Financial Stability Authority makes extensive use of information collected by the Financial Supervisory Authority, and the exchange of information between the authorities is governed by law as well as the cooperation arrangement that specifies the legislative provisions further. The effective exchange of information between the authorities reduces their reporting burden.
The technical specifications, information collection tables and other guidelines drawn up by the European Banking Authority (EBA) and the Single Resolution Board are applied in information collection activities.
As part of the cooperation between European authorities, the Financial Supervisory Authority relays the information it collects to the EU authorities (EBA and SRB) and the Financial Supervisory Authority.
More information on resolution planning is available here.
The collection of information related to resolution planning on 31 December 2020
The Financial Stability Authority collects information from the LSI credit institutions under its remit based on the situation as at 31 December 2020 for the purpose of drafting resolution plans. The collection of information is based on Commission Implementing Regulation (EU) 2018/1624 (CIR Regulation). The information is collected as XBRL reporting in accordance with the RES module of version 2.10 of the EBA’s reporting framework. On 30 October 2020, the Financial Stability Authority sent an information request by e-mail to all LSI credit institutions along with more detailed institution-specific reporting requirements pertaining to the collection of information in question. The due date for the submission of information to the Financial Stability Authority is 30 April 2021.
Starting from 1 March 2021, credit institutions can submit XBRL test reports to the Financial Stability Authority. This means that credit institutions can submit the XBRL files they create to have their technical accuracy verified before the due date of submission in order to ensure that the files are technically valid.
In addition to information collection based on the CIR Regulation, the Financial Stability Authority collects securities-specific debt structure information from LSI credit institutions in Excel format. On 30 October 2020, the Financial Stability Authority sent an Excel form to all LSI credit institutions to be used for the collection of the information in question. The form was sent as an attachment to the e-mail concerning the reporting-related information request. Guidance on filling the form is provided in the SRB document “Guidance on the Liability Data Report”. The due date for the submission of information to the Financial Stability Authority is 30 April 2021.
Information collection related to monitoring the MREL requirement
The quarterly collection of information in Excel format related to the monitoring of the MREL requirement from LSI credit institutions that have a resolution strategy will continue in 2021. The next round of information collection will be based on the situation as at 31 December 2020. More detailed instructions concerning this information collection will be sent to LSI credit institutions that have a resolution strategy as a separate notification.
EBA Draft ITS on disclosure and reporting of MREL and TLAC
In August 2020, the EBA published a draft version of the ITS pertaining to the disclosure and reporting of TLAC and MREL information. These reporting and disclosure requirements only apply to credit institutions that have a resolution strategy.
The reporting requirement takes effect starting from the situation as at 30 June 2021 and the due date for the submission of information is 18 August 2021. The reporting requirement is included in version 3.0 of the EBA reporting framework. This information collection is based on the XBRL format and takes place quarterly.
Pursuant to the Act on the Resolution of Credit Institutions and Investment Firms, banks are required to submit information to the resolution authority and the supervisory authority. The Financial Stability Authority is currently working together with the Financial Supervisory Authority to determine the most efficient way of organising the collection of this information from credit institutions.
The Financial Stability Authority will inform LSI credit institutions that have a resolution strategy by means of institution-specific letters pertaining to the reporting requirement in question (scope, reporting levels, schedules, etc.) and the letters are likely to be sent out in early 2021.
The Financial Stability Authority has yet to decide the extent to which the collection of information pertaining to the reporting requirement in question will replace the current quarterly collection of information related to the monitoring of the MREL requirement. The Financial Stability Authority will inform credit institutions of this by issuing a separate release.
The MREL-related disclosure requirements pursuant to the ITS will take effect in January 2024 at the earliest.
Institution-specific reporting requirements
The Financial Stability Authority announces the scope of information reporting annually along with a description of the technical delivery method of the information in question by sending a letter to the banks and institutions under its remit.