EBA's Initiatives and Guidelines: an Overview

Alessandro Micagni

On May 21st, 2023

In this article, we'll analyze the European Banking Authority's (EBA) recent developments, focusing on their draft guidelines and supervisory benchmarking updates. Our emphasis will be on guidelines regarding historical data resubmission, integral to ensuring accurate reporting.

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The article discusses various developments and consultations initiated by the European Banking Authority (EBA). The EBA is seeking comments on draft guidelines related to resubmission of historical data, simplicity and standardization criteria for securitizations, market risk internal models, and the assessment of credit servicers. The EBA also updated the list of institutions involved in the supervisory benchmarking exercise, published guidelines on supervisory review and evaluation processes, provided results of its quarterly risk dashboard, and answered questions under the Single Rulebook Q&A tool. The key focus is on the guidelines for resubmission of historical data, which aim to ensure accuracy and completeness of reporting obligations.

European Banking Authority's Initiatives

The EBA is inviting comments on draft guidelines concerning the resubmission of historical data under its reporting framework. The guidelines outline a common approach for financial institutions to correct and resubmit data, both for the current reporting date and historical reference dates within the past calendar year.
The guidelines provide exceptions where the resubmission of historical data may not be necessary. They serve as a tool to assist institutions in meeting their reporting obligations accurately, even in the case of errors or inaccuracies.
The EBA acknowledges that the approach presented in these guidelines may differ from existing practices followed by financial institutions when dealing with corrections and resubmissions of historical data.
The EBA is seeking detailed feedback on the possibility of including additional proportionality elements in the guidelines through the consultation process. The guidelines are set to become applicable from December 31, 2023.

EBA: Implications, Consequences, and Hurdles

The introduction of guidelines on the resubmission of historical data under the EBA reporting framework is likely to have several implications and consequences:

Improved Data Accuracy: The guidelines aim to enhance the accuracy and completeness of reported data by requiring financial institutions to resubmit corrected data for the current reporting period and historical data for reference dates within the past year. This will contribute to better data quality and transparency.
Standardized Approach: The common approach outlined in the guidelines will promote consistency across financial institutions in dealing with errors and inaccuracies in reported data. This will facilitate easier comparison and analysis of data within the industry.
Compliance Challenges: Financial institutions may face challenges in ensuring timely and accurate resubmission of historical data, especially if errors or inaccuracies are identified after the reporting deadline. They will need to allocate sufficient resources and develop robust processes to meet the requirements set out in the guidelines.
Feedback and Adaptation: The EBA's call for feedback and suggestions on additional proportionality elements indicates a willingness to refine the guidelines further. The consultation process and subsequent revisions may require financial institutions to adapt their internal procedures and reporting practices to align with the final guidelines.

EBA GUidelines: Ripple Effects

The ripple effects of the guidelines on the resubmission of historical data can extend beyond the immediate impact on financial institutions:

Enhanced Supervision: The availability of accurate and complete historical data will strengthen the EBA's supervisory capabilities. It will enable more effective analysis, risk assessment, and identification of trends or systemic issues in the banking sector.

Market Confidence: The implementation of guidelines that promote data accuracy and transparency can enhance market participants' confidence in the reliability of reported financial information. This may contribute to improved trust and stability in the financial markets.

Regulatory Harmonization: The guidelines align reporting practices across financial institutions, contributing to greater harmonization of regulatory frameworks within the European banking sector. This harmonization can streamline data aggregation and analysis processes for regulatory authorities.

Industry Best Practices: Financial institutions may adopt the guidelines as best practices beyond compliance requirements. These practices can contribute to higher data quality standards, operational efficiency, and risk management within the industry. This may result in improved overall data governance and reporting processes, benefiting the industry as a whole.

Key Assessments and Probabilities

The following table provides an overview of key assessments and associated probabilities related to the discussed developments:

Assessment	Probability	Justification
Adoption of Guidelines	0.9	The EBA's guidelines are typically adopted and implemented by financial institutions to ensure compliance with reporting obligations and to enhance data accuracy and transparency.
	0.7	Financial institutions may face challenges in resubmitting historical data accurately and within the required timeframe due to complex reporting systems and potential data errors.
Enhanced Data Quality	0.8	The guidelines are likely to improve the quality of reported data by establishing a standardized approach to resubmission, reducing errors and inaccuracies in historical data.
Increased Regulatory Oversight	0.9	The guidelines will enhance the EBA's supervisory capabilities by providing access to accurate and complete historical data, leading to increased regulatory oversight of financial institutions.
Market Confidence	0.8	Improved data accuracy and transparency resulting from the guidelines can enhance market participants' confidence in the reliability of financial information reported by institutions.
Regulatory Harmonization	0.7	The guidelines contribute to regulatory harmonization by aligning reporting practices across institutions, leading to greater consistency in data aggregation and analysis for regulatory authorities.
Industry Adoption of Best Practices	0.8	Financial institutions may adopt the guidelines as industry best practices, leading to higher data quality standards, operational efficiency, and improved risk management practices.

European Banking Authority Developments: Thoughts from Grand Compliance

The developments discussed in the article reflect the EBA's efforts to strengthen reporting frameworks and enhance data accuracy within the European banking sector. The guidelines on the resubmission of historical data aim to address errors and inaccuracies in reported data, promoting transparency and improving the quality of information available to regulators and market participants.

The consultation process initiated by the EBA demonstrates a commitment to incorporating stakeholder feedback and refining the guidelines to ensure proportionality and practicality in their implementation. This engagement with industry participants is crucial for the guidelines' effectiveness and the smooth adoption by financial institutions.

The harmonization of reporting practices across institutions can facilitate better data aggregation and analysis for regulatory authorities. It also supports the goal of creating a level playing field within the European banking sector, contributing to increased transparency and market stability.
Financial institutions may face challenges in implementing the guidelines, especially in cases where errors are identified after the reporting deadline.

Adequate resources and robust internal processes will be necessary to meet the resubmission requirements within the specified timeframe. However, the benefits of improved data quality and enhanced regulatory oversight outweigh the potential hurdles.

Overall, these developments signify a step forward in strengthening the regulatory framework and promoting sound data governance practices in the European banking industry. By encouraging accurate and complete reporting, the EBA aims to enhance market confidence, improve risk management, and foster a more transparent and resilient financial sector.