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.
Data collection related to resolution planning for 2022
The Financial Stability Authority will collect data for the reference date 31 December 2021 simultaneously from credit institutions under its purview for the purposes of the preparation of resolution plans. Data collection will be carried out as described in the attached bulletin. Information in addition to what is contained in the attached bulletin is available at tiedonkeruu(at)rvv.fi.
The data collection is based on Commission Implementing Regulation (EU) 2018/1624 (“CIR”). The data was collected in XBRL format in accordance with the specifications of the RES module of the EBA reporting framework, version 2.10. On 30 October 2020, the FFSA sent an information request and more detailed institution-specific reporting requirements pertaining to the data collection by email to all LSIs. The deadline for the submission of the data to the FFSA was 30 April 2021.
As from 1 March 2021, credit institutions were able to submit XBRL test reports to the FFSA. Hence, credit institutions were able to submit the XBRL files generated by them for a technical validation before the submission deadline and thereby ensure the technical validity of the files.
In addition to the data collection based on the CIR, the FFSA collected security-by-security data on liability structure from LSIs in a separate Excel-format data collection. On 30 October 2020, the FFSA sent an email to all LSIs containing the information request and the Excel form used in the data collection as an attachment. Instructions on the completion of the form, as applicable, are available in a document published by the SRB, entitled “Guidance on the Liability Data Report”. The deadline for the submission of the data to the FFSA was 30 April 2021.
Data collection related to monitoring MREL
Each quarter starting from 31 December 2021, the Financial Stability Authority will collect data from certain LSI credit institutions under its purview and with a bankruptcy strategy data for the streamlined monitoring of MREL. The attached bulletin describes in greater detail what the data collection process will actually consist of and the relevant deadlines.
Each quarter starting from 31 December 2021, the Financial Stability Authority will collect from LSA credit institutions under its purview and with a resolution strategy a checklist and management confirmation form to ensure MREL eligibility for the liabilities indicated in the data collection in accordance with the Commission Implementing Regulation on MREL reporting. The attached request for information describes in greater detail what the data collection process will actually consist of and the relevant deadlines.
Information in addition to what is contained in the bulletins is available at tiedonkeruu(at)rvv.fi.
Excel-based quarterly data collection pertaining to MREL monitoring from LSIs with a resolution plan continues in 2021. Next time, the data collection will be concerned with data for 31 March 2021. More detailed instructions related to the data collection have been communicated to LSIs with a resolution strategy in a separate release.
EBA ITS concerning reporting and disclosure of MREL/TLAC
The final implementing technical standards (ITS) of the European Banking Authority (EBA) concerning the requirement of disclosure of the MREL and TLAC requirements and related reporting to the authorities were published on 12 May 2021. The Commission Implementing Regulation concerning EU-level supervisory reporting is found in the paragraph “Useful links” below.
The reporting requirement enters into force as from 30 June 2021, and the first deadline for the submission of the data to the Financial Stability Authority is 30 September 2021. The data do not need to be submitted separately to the FFSA. The reporting requirement concerns banks with a resolution strategy in Finland, and it is carried out on a quarterly basis. The reporting requirement is completed with a separate data collection in an Excel format concerning forecasts on MREL-capacity carried out by banks.
The FFSA has informed LSIs with a resolution strategy by bank-specific information requests concerning the updated MREL -reporting requirements.
The EU-level data collection applies technical specifications and other instructions prepared by the EBA. The reporting requirement is included in the EBA’s reporting framework version 3.0, according to which the information should to be submitted to the FFSA in XBRL format. As part of European cooperation among authorities, the FFSA will forward the data collected by it to EU authorities (EBA and SRB) as well as the Financial Supervisory Authority.
The MREL-related disclosure requirements under the ITS will enter into force at the earliest in January 2024.
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.
- Commission Implementing Regulation (EU) 2018/1624 (CIR Regulation)
- EBA reporting framework version 2.10
- EBA publishes final draft technical standards on disclosure and reporting on MREL and TLAC
- Commission implementing regulation (EU) 2021/763
- EBA reporting framework version 3.0
- SRB 2021 Resolution Reporting
- FFSA briefing of 12 May 2021 (in Finnish)