The EACB comments the SRB consultation regarding its updated Expectations on Valuation Capabilities (EoVC). The EACB welcomes the SRB's efforts to improve the standardised data set and reduce the administrative burden associated with reporting by relying on existing common definitions and EU standards. However, we express concern about the extensive scope and frequency of the required reporting in relation to the SRB Valuation Data Set, Trial Balance Extracts, interim reports, shareholder data, and external rating reports, as main examples. Annex 1 (page 75) lists a variety of more than 40 documents to be submitted on semi-annual basis on a single-entity basis within a short time frame (within 45 calendar days from the cut-off date).
We highlight that the set-up and maintenance of a permanent DRR infrastructure with a very large amount of data appears to go well beyond the mandate for a set of SRB expectations, also considering that it would create a new and extensive set of reporting obligations that appear more suited to be established under a level 1 mandate. There is a clear risk to establish highly costly requirements via soft law. This also seems to be in contrast with ongoing initiatives for a simplification and more effective policy making. We urge the SRB to reconsider the requirement of a permanent repository and to limit the population of the DRR to dry-runs and other tests, where applicable.
Regarding the submission across the group, several strategic are defined at the consolidated level and do not exist on a solo basis. Requiring individual submissions for each entity would lead to duplication and redundancy. In addition, single-entity data is not always available. We believe that consolidated reporting should waive reports for each institution within an IPS or group affiliated structure. Limitations also persist in data reconciliation. In practice, reconciliation of data fields across different reporting levels and templates is sometimes not feasible due to structural and technical limitations and cannot be guaranteed in every case. Key challenges include differences in aggregation levels (solo vs. consolidated), as well as the lack of semi-annual data.
Concerns are raised about the feasibility of the proposed implementation timeline, emphasizing the need for adequate time, resources, and security measures to ensure compliance. We recommend aligning the implementation deadlines for the data repository and valuation documentation with practical considerations and suggest simplifying governance requirements to avoid unnecessary duplication and complexity.