Societe Generale - European Banking Authority - Europa

Detailed answers to questions for ConsultationCHAPTER 1Subject matter, Scope and Definitions1. How would you assess the cost impact of using only CRR scope of consolidation forsupervisory reporting of financial information?As we already produce detailed financial statements on the CRR scope for supervisorypurposes, there is no cost impact of using only CRR consolidation scope ofconsolidation.2. Please specify cost implications if parts 1 and 2 of Annex III and of Annex IV of thisregulation would be required, in addition to the CRR scope of consolidation, with theaccounting scope of consolidation?There would be an important additional cost if the accounting scope of consolidationwould be used because we do not collect detailed data for the non Basel regulatedactivities of the Group as they are not within the scope of Basel requirements.According to the non use of the data, we do not collect the breakdown of financialassets by counterparty for the insurance activity which stand for about 60% of our debtinstruments classified as available for sale and 8 % of our financial assets excludingderivatives at fair value through profit and loss. Reporting the FINREP project on anaccounting scope would mean to extend our risk database to the insurance activityand to include this activity into the accounting / risk data reconciliation only for theFINREP purpose.CHAPTER 2Reporting reference and remittance dates3. Financial information will also be used on a cross-border and on European level, requiringadjustments to enable comparability. How would you assess the impact if the last sentence ofpoint 2 of Article 3 referred to the calendar year instead of the accounting year?As our accounting year is a calendar year, this last sentence has no impact for us.4. Does having the same remittance period for reporting on an individual and a consolidatedlevel allow for a more streamlined reporting process?Most of the data calculation for Basel and CRD are done once by the centraldepartment of the Group and then the results are sent back to the entities. Because ofthat, it is not possible to have the same remittance date for both reporting (individualand consolidated). The same dates would shorten the time limit to produce theconsolidated reporting in order to respect the individual ones. Furthermore, we do notunderstand the need and use of individual data as the CRD data are required and3

monitored on a consolidated basis. We also lean on individual COREP and minimisethe risk of discrepancies between the individual and consolidated COREPMoreover, as we do not have to produce our individual financial statement under theIFRS, the IFRS data on an individual basis are not available (as far as individualfinancial statements under IFRS are not similar to individual contribution toconsolidated data under IFRS, taking into consideration the effect of businesscombination adjustments for instance). Reporting simultaneously on an individualbasis FINREP data according to IFRS and financial statements according to thenational accounting framework would be a very significant additional and costly work.Having the same remittance period for reporting on an individual and a consolidatedlevel would not allow for a more streamlined reporting. It would reduce our internaldeadlines in order to deal with the discrepancies between the individual andconsolidated reporting.5. How would you assess the impact if remittance dates were different on an individual levelfrom those on a consolidated level?See our answer to question 46. When would be the earliest point in time to submit audited figures?Our regulatory reporting is not audited.As we are a listed company, we have to issue our financial statements (includingdisclosures) and our registration document with audited figures. We usually issue themabout 45 calendar days after the closing date. When the financial statements areready, while our auditors are completing their certifications, we prepare the FINREP,COREP and national reporting. By the end of 60 calendar days we can provide figuresbased on the audited financial statements.Nowadays, we first produce our consolidated financial statements (under IFRS) andthe Parent company financial statements (under French GAAP) in order to fulfil thefinancial market regulation. We then publish the registration document with financialstatements fully audited about 60 days after the closing date. During the first 30 dayswe work only on the financial statements, then during the next 30 days we worksimultaneously on the financial statements, the FINREP and COREP and the localreporting to be sent to our national supervisory authority.Reducing the deadlines may create a potential bottleneck effect in our accounting andrisk departments.7. Do you see any conflicts regarding remittance deadlines between prudential and otherreporting (e.g. reporting for statistical or other purposes)?4

As explained in our answer to the previous question, we first work on the financialstatements and the run of the risk calculators. Then we begin to work on FINREP andCOREP with almost final figures. If we have to produce FINREP and /or COREPbefore financial figures are stabilized, we will not be able any more to have asequential production of the reporting and of the financial statements, we will have toparallelise the works and to double the manpower. The cost would be high for noimprovement of the quality of the reporting.CHAPTER 3Format and frequency of reporting on own funds requirements8. Do the proposed criteria lead to a reduced reporting burden?The proposed criteria might lead to increase reporting burden because we have toproduce all the figures to check the thresholds.9. What proportion of your total foreign exposures would be covered when applying theproposed thresholds? Please also specify the number of countries that would be covered withthe proposed threshold as well as the total number of countries per exposure class.Regarding the non retail exposures, 63% of the total foreign exposures and 57countries would be covered :23 countries for foreign exposures on corporates,4 countries for foreign exposures on SME,47 countries for foreign specialized lendings,21 countries for foreign exposures on banks,3 countries for foreign exposures on central banks and sovereigns,7 countries for foreign exposures on public sector entities.10. What would be the cost implications if the second threshold of Article 5 (1) (c) (ii) weredeleted?We would have to disclose a template for more than 150 countries.11. Is the calculation of the threshold sufficiently clear?Actually, we need additional guidelines on the definition of the “original exposure” andthe “foreign exposure”. Shall we disclose the exposures according to the booking5

entity, the asset location country of the obligor, the originating country of the assets(….) ?12. Do the provisions of Article 5 (2) lead to a reduced reporting burden for small domesticinstitutions?Not applicable13. Is the calculation of the threshold sufficiently clear?As put above, we need additional guidance of the geographical distribution ofexposures.14. Competent Authorities are obliged to disclose data on the national banking sector‟s totalassets as part of the supervisory disclosure. Do you find these publications sufficient tocalculate the proposed threshold?Our understanding of the threshold is based on our own exposures. If it is correct, wedo not need national banking sectors’ publications to calculate the proposed threshold.15. What would be the cost implications if information on own funds as put forward in Part 1of Annex I (CA 1 to CA 5) were required with a monthly frequency for all institutions?Nowadays, we publish the information concerning own funds requirements on aquarterly bases. Moreover, technically, we cannot produce the information related tothe own funds on a monthly basis, which demand a lot of development in our dataproduction line (eg. Consistency risk/accounting).If we should publish the information on a monthly base, the costs will be, at least,tripled.Format and frequency of reporting on financial information16. Are there specific situations where this approach (differentiating between institutions usingIFRS and national accounting frameworks for supervisory reporting purposes) would not beapplicable?As said in the cover letter, we focused on the templates based on IFRS.17. What is your assessment of impact, costs and benefits related to the extent of financialinformation as covered by Articles 8and 9?As we do not publish the disclosures of our financial statements quarterly, theextension of the FINREP requirement would cost as much as an annual closing, onlyfor supervisory purposes. Most of the breakdown proportions do not changesignificantly from a quarter to another. We could provide a selected package of dataon quarterly basis to balance costs and needs. We provide, in our answer to question33 and in the appendix 1, detailed comments about each table and a proposal offrequency and first remittance date.18. In Articles 8(2) and 9(2) the proposed frequency is semi-annually. Does this reducereporting burden? Please quantify the estimated cost impact of reporting with semi-annualfrequency compared to quarterly.6

Limiting such frequency to only 2 tables over about 60 is not enough to be consideredas reducing reporting burden.19. What is your general assessment of applying reporting standards regarding financialinformation on an individual level?In France, as many countries through the Union, financial institutions already producea very detailed monthly reporting on an individual level. This reporting is based on thelocal accounting rules and answers needs of various statistical requirements.Producing FINREP on an individual level would be a very expensive additional work ifno local reporting is simultaneously withdrawn. It would create heavy reporting burdenand will not fit the various statistical needs. Most of the local breakdowns ofaccounting data are not the same as those required in FINREP. Such a change wouldimply important IT developments and would break the existing statistical series.20. How would you assess costs and benefits of applying the ITS requirements regardingfinancial information on an individual level? (Please assess the impact for the two scenarios (i)application of parts 1 and 2 of Annex III and Annex IV on an individual level (ii) application ofparts 1 to 4 of Annex III and Annex IV on an individual level (ii)) Would there be obstacles forapplying reporting on an individual level?As far as IFRS are not used as local GAAP in France and as long as there is tax andlegal restrictions about this use, implementing FINREP on an individual level would bevery expensive. Some of our foreign subsidiaries that are allowed to use IFRS in theirlocal statements might have lower costs of implementation and sometimes evenalready produce FINREP on an individual basis.We believe that each national supervisor should be allowed, but should not be obliged,to use FINREP on an individual basis. Consequently FINREP on an individual basisshould be out of the scope of ITS.21. If the proposal was to be extended, what implementation time would be needed?We cannot estimate the implementation time if the proposal would be extendedbecause we would have to manage two projects at the same time, one to implementFINREP and the other one to dismantle the existing local reporting.CHAPTER 6IT solutions22. What cost implications would arise if the use of XBRL taxonomies would be a mandatoryrequirement in Europe for the submission of ITS-related data to competent authorities?We already use XBRL taxonomy for FINREP, COREP and our national reporting, thetranslation into the XBRL taxonomy is included into the software we use to built up thereporting and the update are provided by our supplier. In order to have a correct7

project process, we will need to have the reporting table with the ITS and the XBRLtaxonomy at the same time .CHAPTER 7Final provisions23. How would you assess the cost implications of the following two options?(1) Implement the ITS as of the first possible reference date (31/03/2013)2) Delay the implementation of the ITS by 6 months (first reporting based on data as of30/09/2013) and implement national interim solutions for reporting as of 31/03/2013.Option 1 is impossible due to the number of data required in this reporting proposalwhich are not directly available in a unique database. We have to connect differentdatabases and to build up the reconciliation processes.Option 2 is a better alternative although the implementation delay is not long enough.We provide in our answer to question 33 and the appendix 1 a proposal of frequencyand first remittance date, starting at the 31/03/2013 for the COREP own fundstemplates.24. What would be the minimum implementation period to adjust IT and reporting systems tomeet the new ITS reporting requirements? Please elaborate on the challenges which couldarise.Implementing the FINREP as proposed in this consultation is an important IT andprocess project for the Group. We would have to create automatic connectionsbetween our risk and finance data systems and data collectors, we would have tocollect additional information which are not currently available in our informationsystem and as they are not used for accounting nor for management purposes. Thisproject would have to be thought and designed in a cohesive way with our internalimprovements. We also need to have the global picture of all the forthcoming reportingrequirements including IFRS. This kind of project is not a short term one but a longterm one which usually needs about two years of work. Consequently, animplementation of the ITS as of 31/03/2013 is almost impossible. A delay of theimplementation and national interim solutions is the best alternative. But thisalternative should be used during more than 6 months. It should be used until we havea real automatic implementation of the ITS and the update of IFRSs. Including theIFRS project in the target will avoid additional cost and the use of a very temporaryFINREP. We think that the COREP implementation could be finalised in 2014 andFINREP in 2015. Please see our answer to question 33 and annexe 1 for the detailedpath and the tables we could provide before the end of the implantation period.8

25. What would be the minimum implementation period required for institutions alreadysubject to FINREP reporting to implement the financial reporting described in this consultationpaper ?See our answer to question 24. Even if we already provide a very detailed FINREP,the implementation period could not be shortened. But we can already provide manytables and some additional breakdowns (see answer to question 33 and appendix 1).The additional requirements are the most costly and they amount for more of 80% ofthe cost of the project.26. What would be the minimum implementation period required for institutions NOT subjectto FINREP reporting at the moment to implement the financial reporting described in thisconsultation paper?If FINREP requirements are closed to financial statements, their implementation periodis rather short. The mix of risk and finance data, plus the specific FINREP information,that is information NOT required by the IFRS or national accounting rulesrequirements, lengthens the period of implementation to a minimum of 2 years.27. Would the required implementation period be the same for reporting requirements on anindividual basis and on a consolidated basis?See answer to question 21Annex I and Annex II28. Do restrictions (restricted cells are cells which do not have to be reported to supervisors -displayed in the COREP templates as grey/blocked cells) reduce the reporting burden?Currently, our COREP templates consist blocked cells, which are useful for us.29. Compared to previous versions of the COREP templates are there additional reportingrequirements which, cause disproportionate costs?What will almost cause disproportionate costs for us is the reduced deadline for theCOREP production. As you may know, our IT system is very complex and heavy. It isnot conceivable for us to realise the production line development and produce the newCOREP templates in the reduced time limit.Moreover, the collection of additional data will cause important costs.30. Are the templates, related instructions and validation rules included in Annex I and AnnexII sufficiently clear? Please provide concrete examples where the implementation instructionsare not clear to you.We would like additional guidelines on the following items :* Template CR SA :9

(i) we need additional guidance on the disclosure regarding “subject to CVA charge”(row 50)? Do we have to disclose in the rows the exposure value of instruments thatare in the scope of CVA or the CVA charge per itself?(ii) Comparing CR SA and CR SA details, we notice that off-balance sheet itemsregarding Default funds are blocked in the CR SA Details (row 30/column 20) but notin the CR SA. Is it an omission ?* Template CR IRB :(i) may you confirm that column 271 requires disclosing accounting CVA ?(ii) Row 150 / column 10 is not blocked: may you confirm that this is an omission ?(iii) We need additional guidance on the disclosure concerning “number of obligors”(column 280) versus “number of counterparties” (column 290): what’s the differencebetween the obligors and the counterparty? Why all the cells are blocked except row041, 050 and 051 for the number of counterparties? How to fill them?Template MKR SA EQUA new disclosure is required regarding the threshold of 2% of the sum of the totalgross long and gross short positions for all equity positions. We need additionalguidance about the definition of the “national market”.What is the meaning of (net + short) in the template? Do you mean (long + short)?* Template MKR IM :A new disclosure is required regarding a split per currency which will lead to ITdevelopments. Also, we need additional guidance about the gross positions : what isthe meaning of (net + short) in row 190 01-N ? Do you mean (long + short)?*Template CR Sec SA :May you confirm that we need to disclose IAA approach (row 310-320) in thestandardised template ? And what is the reason of the disclosure?*Template SEC Detail:May you confirm that the scope of the disclosure is limited to the non-trading bookelements?10

31. CR IRB – What is your assessment of cost implications of the new lines for “largeregulated financial entities and to unregulated financial entities”? What is the most costefficient way of incorporating this kind of information in the reporting framework?This information is required by the CRD4, but not an additional requirement ofCOREP. Therefore, the only implementation of the new line in COREP does notgenerate supplemental costs. Indeed, the costs will be generated in the level ofimplementation of CRD4.32. CR SA – What is your assessment of cost implications of the new lines to gatherinformation about exposures without a rating or which have an inferred rating? What is themost cost efficient way of incorporating this kind of information in the reporting framework?As put above in the question 31Annex III, Annex IV, and Annex V33. Are the templates included in Annex III and Annex IV and the related instructions includedin Annex V sufficiently clear? Please provide concrete examples where the implementationinstructions are not clear to you.In a table in annexe 1 we underline the main difficulties we could meet to implementthe tables and propose solutions to avoid additional reporting burdens and an interimsolution.Template 10 (Annex III and Annex IV)34. Do the provisions of Article 8 (3) and 11 (3) lead to a reduced reporting burden?These ITS are part of the single rulebook enhancing regulatory harmonisation inEurope which is welcome by the institutions because it will ensure fair condition ofcompetition between comparable groups and because it will reduce reporting burdenfor the trans-border groups. For a trans-border group the provision of Article 8 (3) and11 (3) cannot reduce reporting burden. The provisions of these articles may reduce thereporting burden only for small national institutions.35. What are the cost implications of introducing a breakdown by individual countries andcounterparties?We understand that as we are an international group, according to art 8, we’ll have tocalculate for each reporting the amount of exposure on each country and then selectthe 10 biggest to fill up the table. The cost to build up an automatic system to preparethe data is very high and then the analyse of the data to identify the data to report isalso very high.We already produce a reporting for BSI international consolidated banking statisticsand COREP will provide a breakdown by country. This FINREP table create heavy11

eporting burden and do not provide additional information. Why is there a need tomap this information of this table with the PD LGD information in COREP ? Westrongly disagree to send two (or three) similar tables. We think that this table shouldbe deleted.36. What are the cost implications of introducing a breakdown by economic sector by usingNACE codes?The breakdown by economic sector by using NACE code is an additional breakdown.We already use it for monetary national statistics and we do not understand the use ofthese codes on a consolidated base. What is the need fed by this requirement ? Thecost of using so many different economic sectors is linked to the maintenance of thedata references. But we believe that the costs that would be cumulatively incurred bybanks to provide similar data splitted according to different breakdowns significantlyexceed the advantage that would be expected by some of their users wishing to keepconsistency with existing statistical series.37. Would other classification be more suitable or cost efficient?A real harmonisation of the various economic sectors which are currently different fromFINREP and COREP, MIR and BIS statistics would be very cost efficient. We wish theJEGR works could be achieved and provide this harmonisation.38. What would be the difference in cost if the geographical breakdown would be asked onlyby differentiating between domestic and foreign exposures compared to country-by-countrybreakdown?A geographic breakdown by country will enhance a regulatory harmonisation inEurope. The reporting format would be the same for all the subsidiaries of a transbordergroup. But this option is quite expensive because links between accounting andthe counterparty data base will have to be implemented.Differentiating breakdown between domestic and foreign exposures would be muchcheaper and easier to produce if based upon the booking criteria.39. What are the cost implications of introducing breakdown of sovereign holdings by country,maturity and accounting portfolio?Because of the ad hoc reporting requirement, we already provide detailed data aboutsovereign exposure. There will be few additional costs.12

Template 14 (Annex III and Annex IV)40. How would you assess the cost implications on providing a geographical breakdown ofthese items with the proposed breakdown to domestic, EMU countries, other EU and rest of theworld?On one hand, our data base could provide the residence of the counterparty of our riskexposure because this information is used in the risk management. On the other hand,we do not know the residence of all our liability holders, notably when traded on amarket.The breakdown of the interest margin by residence of the counterparty is a matter forcost accounting, it does not belong to the IFRS accounting.We do not understand the use of a geographical breakdown in FINREP as it alreadyexists in COREP and in BSI international consolidated banking statistics for the assetsside. This table seems to be quite similar to table 10. We strongly disagree to sendtwo (or three) similar tables. We think that this table should be deleted.41. Would application of a materiality threshold similar to Article 8 (3) and 11 (3) (reportingthe breakdown only if foreign exposures exceed 10 % of the total exposures) reduce reportingburden?We do not think so. See our answer to Q 3442. What would be difference in cost implications if breakdown would be requested only withdifferentiation between domestic/ foreign or alternatively country by country with similarthreshold than in Article 8 (3) and 11 (3) compared to the proposal in the Consultation Paper?We do not think so. See our answer to question 34Templates for reporting financial information according to national accounting frameworks43. Are there specific aspects of national accounting framework that has not been covered ornot addressed properly in the templates?Instructions in Annex V44. Does the IAS 7 definition of cash equivalents follow the practice used when publishingfinancial statements? How would this definition interact with definitions of IAS 39 for assets inheld for trading portfolio?The IAS 7 definition of cash equivalent does not follow the practice used in thepublished balance sheet, it is only used for the Statement of Cash Flows which is notmeaningful for a financial institution. But there is no specific difficulty to fulfil this IAS 7requirement.13

45. How do you assess the impact of reporting interest income and interest expense fromfinancial instruments held for trading and carried at fair value through profit and loss alwaysunder interest income and interest expense?We report net gains and losses on financial instruments at fair value through P&L.Extracting the interest incomes or expenses on this instruments is not possible in ouractual management system and does not fit with the way they are valued andmanaged and the way their result is recognised. The fair value measurement, inparticular for the listed instruments, is a global valuation which does not split eachcomponent of the price in the accounting system. Reporting interest income andinterest expense on financial instruments held for trading and carried at fair valuethrough profit and loss would be a very artificial and expensive exercise performed forthe FINREP purpose only and with neither economic nor accounting meaning. Thealternatives and options allowed by IFRS for the presentation of Profit and Lossshould not be deleted..14

Annexe 1 – Detailed answer to question 33 and proposal of first remittance date and frequencyPart 1 - FINREP11.11.2ITS ON SUPERVISORYREPORTING – EBA CP 50ANNEXES IIIPART 1Balance Sheet Statement(Statement of FinancialPosition)Balance Sheet Statement:assetsBalance Sheet Statement:liabilities1.3 Balance Sheet Statement: equity2 Income StatementCOMMENTSInterest income and interest expense fromfinancial instruments held for trading, and fromfinancial instruments carried at fair value throughprofit or loss, cannot be reported separately fromother gains and losses under items “interestincome” and “interest expense” because theirinterest are included into their fair value . Seeanswer to Q 45PROPOSALOFFREQUENCYPROPOSALOF FIRSTREMITTANCEDATEQuarterly - 31/03/2013Quarterly - 31/03/2013Quarterly - 31/03/2013Quarterly - 31/03/2013with no changein interestincome andexpensesPART 2

33.13.2ITS ON SUPERVISORYREPORTING – EBA CP 50Breakdown of financial assetsby instrument and by assetclassBreakdown of financial assets byinstrument and by asset class:demand deposits and cashequivalentsBreakdown of financial assets byinstrument and by asset class:financial assets held for tradingCOMMENTSIs the economic sector for the equity instrument,the issuer’s one ?IFRS 7 – (c) requires the amount of change,during the period and cumulatively, in the fairvalue of the financial asset that is attributable tochanges in the credit risk only for financial assetsor financial liabilities at fair value through profit orloss.- The changes of faire value come fromvarious risks ( interest rates, credit, FX…) .It isnot possible to isolate each component throughthe accounting reporting. Such detail is onlyavailable from the front office or the middle officeor the risk management system according to therisk- It is not possible to get such a detailedinformation broken down by sector classes.- Furthermore, as the fair value is only oneamount in the accounting system, the detailedchanges in fair value require to keep and analysethe slit of the value from the beginning to the endof the period .PROPOSALOFFREQUENCYPROPOSALOF FIRSTREMITTANCEDATEHalf yearly – 30/06/2013Half yearly – 30/06/2013without thecolumn 020and line 02016

3.4ITS ON SUPERVISORYREPORTING – EBA CP 50Breakdown of financial assets byinstrument and by asset class:financial assets designated atfair value through profit or lossCOMMENTS- Is the economic sector for the equityinstrument, the issuer’s one ?- Is the economic sector for the equityinstrument, the issuer’s one ?- See table 3.2PROPOSALOFFREQUENCYPROPOSALOF FIRSTREMITTANCEDATEHalf yearly – 30/06/2013without thecolumn 020and line 0203.53.8Breakdown of financial assets byinstrument and by asset class:available-for-sale financialassetsBreakdown of financial assets byinstrument and by asset class:Loans and receivables and heldto-maturityinvestmentsIs the economic sector for the equity instrument,the issuer’s one ?- there is not IFRS requirement to identify« Specific allowances for individually assessedfinancial assets” and “Specific allowances forcollectively assessed financial assets”Half yearly – 30/06/2013without thecolumn 020Half yearly – 30/06/2013with only onecolumn for the040 and 03044.1Past due, impaired anddefaulted assetsFinancial assets subject toimpairment that are past due orimpaired- Is the economic sector for the equityinstrument, the issuer’s one ?- The impairment of equity instrumentscannot be reported for those at fair value on thebalance sheet because- The breakdown of the « Loans andadvances » by counterparty and product, that isaccording to two differentiation axis requiresQuarterly - 31/03/2013without line010 to 050and 210 to300 and col100 filled uponly for line12017

ITS ON SUPERVISORYREPORTING – EBA CP 50COMMENTSimportant changes in our data bases. A singleaxis could be much more cheaper and the onealready available is by counterparty.- How should “Collateral and other creditenhancements received as security for therelated impaired and past due assets” bereported, according to the loans or to their owncharacteristics. COREP already collect a similarinformation .- « Specific allowances for collectivelyassessed financial assets » cannot be brokendown by counterparty, neither by product as theyare not individually affected.- What is the difference between col 100and 150 ,PROPOSALOFFREQUENCYPROPOSALOF FIRSTREMITTANCEDATE4.2Financial assets non-subject toimpairment that are past due- What is the difference between not defaultand not impaired ? The mix of the IFRSdefinitions and the CRR ones are confusing- We think that table 4.1 should cover allthe data, what could be Assets non subject toimpairment ?Thisshoulddeletedtablebe18

5ITS ON SUPERVISORYREPORTING – EBA CP 50Breakdown of financial liabilitiesby product and by counterpartyCOMMENTSIFRS 7 – (c) requires the amount of change,during the period and cumulatively, in the fairvalue of the financial asset that is attributable tochanges in the credit risk only for financial assetsor financial liabilities at fair value through profit orloss.PROPOSALOFFREQUENCYHalf yearlywithout column060PROPOSALOF FIRSTREMITTANCEDATE– 31/12/201366.16.2Loan commitments, financialguarantees and othercommitmentsOff-balance sheet items subjectto credit risk: loan commitments,financial guarantees and othercommitments givenLoan commitments, financialguarantees and othercommitments receivedPART 37 Derivatives: held for tradingThe maximum guarantee that can be consideredis used for the COREP calculation, so this tableshould be deleted from FINREP- There is no definition of Economic hedgein the IFRS .- The financial instrument are notaccounted by instrument and economic sectorclass, they are accounted by classes andcategory.- To fill up the last three lines of the table 3and 4, a breakdown of the total by counterparty isHalf yearly – 31/12/2013This tableshould bedeletedHalf yearly – 30/06/2013withouteconomichedge andwithout line260 to 28019

ITS ON SUPERVISORYREPORTING – EBA CP 50COMMENTSnecessary. This information is not alreadyavailable in our data systems.- Some derivatives stand on the asset sideor liability side of the balance sheet according totheir value without any possible link between thebalance sheet amount and the notional one.PROPOSALOFFREQUENCYPROPOSALOF FIRSTREMITTANCEDATE8 Derivatives: hedge accounting9Breakdown of loans andadvances by product10 Credit risk10.110.2Geographical breakdown offinancial exposures subject tocredit risk by residence of thecounterpartyBreakdown of loans andadvances to non-financialSee table 7 Half yearly – 30/06/2013without line430 to 450- We already produce a similar table on an This tableindividual basis for the ECB statistics. What need should bethis additional table will feed.deletedSee Q 35 to 39We do need to have the list of the ten countriesof the table.What is the need to add the “of which:Commercial real state and Small and mediumsized enterprises (SME) “ ?We already produce a very similar table for oursupervisor, based on the consolidated data andfeeding the BRI requirement . This additionaltable increase the reporting burdenSee Q 35 to 39What is the need fed by this table . It seems to beThis tableshould bedeletedThis tableshould be20

10.3ITS ON SUPERVISORYREPORTING – EBA CP 50corporations by NACE codesGeographical breakdown of debtsecurities held from generalgovernments by residence of thecounterparty and by residualmaturity11 Impairment11.111.212Impaiment on financial and nonfinancialassetsMovements in allowances forcredit losses and impairment ofequity instrumentsFinancial assets pledged ascollateral: derecognition andfinancial liabilities associatedwith transferred financialassetsCOMMENTSPROPOSALOFFREQUENCYPROPOSALOF FIRSTREMITTANCEDATEfor statistical purposes and not for supervisory deletedreporting.See Q 35 to 39 Quarterly - 31/03/2013The Breakdown by economic sector are notavailable by flowsWhat is the meaning of “ estimated probable loanlosses “ , what is it based on ?- Are the Repos included or not in thistable ?.- The col 110 is not an IFRS requirementHalf yearly – 30/06/2013Half yearly – 30/06/2013without thebreakdown byeconomicsectors.Instructions arerequired aboutof “ estimatedprobable loanlosses “Yearly - 31/12/2013without col 11021

13ITS ON SUPERVISORYREPORTING – EBA CP 50Fair value hierarchy: financialinstruments at fair valueCOMMENTS- The hierarchy level of the instrument isnot available in the accounting data becauseaccounting is made according to theclassification of the IFRS and detailed intocategory such as debt instruments, of equityinstruments. Le level of an instrument maychange during its life the trading protofolio is notmanaged in a way which allows to identify in theaccounts the difference between realised andunrealised result .- IFRS7 and IFRS 13 requires informationabout level 3 instrument . Unrealised gains andlosses for Level 2 and 1 instruments are notIFRS requirements . The way a trading portofoliois managed do not pay attention about unrealisedgains or losses particularly on Level 1instruments.IFRS13 is not yet approved by the EUPROPOSALOFFREQUENCYHalf yearlyYearlyThe data notrequieredeither by IFRS7 or by IFRS13 should bedeleted.PROPOSALOF FIRSTREMITTANCEDATE– 30/06/2013for column 010to 030– 31/12/2013for column 050and 08014 Geographical breakdown14.1Geographical breakdown ofassets by residence of thecounterpartyWe already provide a similar table based on theBRI needs . A breakdown by counterparty andthen by residence of the counterparty is a realreporting burden .See answer toQ 4022

14.214.314.414.514.6ITS ON SUPERVISORYREPORTING – EBA CP 50Geographical breakdown ofliabilities by residence of thecounterpartyGeographical breakdown ofselected income statement itemsby residence of the counterpartyGeographical breakdown ofassets by location of theactivitiesGeographical breakdown ofliabilities by location of theactivitiesGeographical breakdown ofmain income statement items byCOMMENTSWhat counterparty should be taken into accountfor short positions , is it the issuer of theinstruments ? A breakdown by counterparty andthen by residence of the counterparty is a realreporting burden .We do not always have the counterparty of theliabilitiesSee Q 40 . This deals with cost accounting , notwith IFRS accounting. We do not collect anybreakdown of the interest margin but byclassification of the instrument.If based upon the booking entity, this table isfeasible.If based upon the booking entity, this table isfeasible.If based upon the booking entity, this table isfeasible.PROPOSALOFFREQUENCYSee answer toQ 40See answer toQ 40YearlyYearlyYearlyPROPOSALOF FIRSTREMITTANCEDATE– 31/12/2013 Ifbased uponthe bookingentity,otherwiseshould bedeleted– 31/12/2013 Ifbased uponthe bookingentity,otherwiseshould bedeleted– 31/12/2013 Ifbased upon23

15161717.117.2ITS ON SUPERVISORYREPORTING – EBA CP 50location of the activitiesOff-balance sheet activities:Interests in unconsolidatedstructured entitiesRelated parties: amountspayable to and amountsreceivableBreakdown of selectedincome statement itemsInterest income and expensesby instrument, asset class andcounterpartyRealised gains and losses onfinancial assets and liabilities notmeasured at fair value throughprofit or loss by instrumentCOMMENTSIFRS 12 is not yet adopted by the EU . Whenadopted, this table should not ask for more thanIFRS12- The income statement is either by natureor by destination. There is no accountingrequirement to have both and the accountingrecording are not made to be multidimensional.The income and expenses by counterparty is notpossible. The breakdown by counterparty shouldbe deleted and consequently, this table toobecause giving no additional information thantable 2These requirements do not belong to the IFRS .What need are fed with it ?PROPOSALOFFREQUENCYYearlyPROPOSALOF FIRSTREMITTANCEDATEthe bookingentity,otherwiseshould bedeleted– according toEU approval ofIFRS10 to 12Yearly 31/12/2013ThisshoulddeletedThis tableshould bedeletedtablebe24

17.317.417.517.61819ITS ON SUPERVISORYREPORTING – EBA CP 50Gains and losses on financialassets and liabilities held fortrading by instrumentGains and losses on financialassets and liabilities held fortrading by riskGains and losses on financialassets and liabilities designatedat fair value through profit or lossby instrumentGains and losses from hedgeaccountingFee and comission income andexpenses by activityPART 4Statement of comprehensiveincomeCOMMENTSWe understand that the grey column do need tobe filled upIFRS 7 – (c) requires the amount of change,during the period and cumulatively, in the fairvalue of the financial asset that is attributable tochanges in the credit risk only for financial assetsor financial liabilities at fair value through profit orloss.As the fair value is only one amount in theaccounting system, the detailed changes in fairvalue are not available See table 3.2 .The split between gain and losses has nomeaning- The breakdown by economic sector is notavailable for the income statement- According to IAS 1 (BC 65), the items ofthe other comprehensive income can be detailedeither net of taxes or before taxes. This optionPROPOSALOFFREQUENCYPROPOSALOF FIRSTREMITTANCEDATEHalf yearly – 30/06/2013Half yearly – 30/06/2013for the column010Half yearly – 30/06/2013without column0040Half yearly – 30/06/2013Yearly 31/12/2013without line089 to 110QuarterlyFormat to bereviewed31/03/201325

ITS ON SUPERVISORYREPORTING – EBA CP 50COMMENTSshould not be removed because of the EBAreporting.PROPOSALOFFREQUENCYPROPOSALOF FIRSTREMITTANCEDATE20 Equity20.1 Statement of changes in equity20.2 Capital by counterparty2121.121.221.3PART 5Collateral and guaranteesreceivedBreakdown of loans andadvances by collateral andguaranteesFinancial Assets designated atfair value through profit or loss:mitigation of credit risk withcredit derivativesCollateral held when thereporting institution is permittedto sell or repledge in theabsence of default by the ownerof collateralWe do not always know who are the holders ofour capital., when listed for instance.Is part 5 a block of tables or will thecompetent authority be allowed to choosewhich table is useful for their supervision ?Most of the collateral are not recorded in thebalance sheet, neither off balance sheet. Thesedata are collected for risk management,impairment calculations and COREP. they shouldnot take place in a financial reporting.The accounting data do not carry any breakdownof loans by collateral or guarantee, thisinformation might be only in COREP.Yearly31/12/2013Yearly if askedby the nationalsupervisorThis tableshould bedeleted26

21.4ITS ON SUPERVISORYREPORTING – EBA CP 50Collateral obtained by takingpossession during the periodCOMMENTSThere can be a long time between the start of alegal actions to get the collateral and takingpossession of it. These information is consistentonly on an annual basisPROPOSALOFFREQUENCYPROPOSALOF FIRSTREMITTANCEDATEForeclosure [tangible assets]21.5accumulatedFinancial assets pledged as22collateralFinancial assets pledged as22.1 collateral for liabilities andcontigent liabilitiesFinancial assets pledged asnon-cash collateral for which thetransferre has the right to sell or22.2repledge in the absence ofdefault by the reportinginstitution23 Fair value23.1Fair value hierarchy: financialinstruments at amortised costThis table does not fit with IFRS 7- 38If asked , this table should be a yearly oneIf asked , this table should be a yearly one- IFRS 13 is not yet adopted by the EU .We do believe that the fair value hierarchy forfinancial instruments at cost give no consistentinformation, in particular for the loans for whichthere is no active market , which is the case ofour originated loans.27

ITS ON SUPERVISORYREPORTING – EBA CP 5023.2 Use of the Fair Value Option23.324Hybrid financial instruments notdesignated at fair value throughprofit or lossOff-balance sheet activities:asset management, custody andother service functionsCOMMENTSIf asked , this table should be a yearly oneHybrid financial instruments not designated at fairvalue through profit or loss cannot be identifiedthrough the accounting data;- The Financial data are collected in orderto produce the IFRS financial statement. Asthese data are required by the IFRS, we do notcollect it to consolidate it. Financial informationnot required by IFRS should not be collected andshould be removed .-PROPOSALOFFREQUENCYThisshoulddeletedtablebePROPOSALOF FIRSTREMITTANCEDATE25 Tangible and intangible assetsTangible and intangible assets:25.1carrying amountTangible and intangible assets:25.2assets subject to operating lease26 Provisions If asked , this table should be a yearly one27Defined benefit plans andemployee benefits27.127.2Components of defined benefitplan assets and liabilitiesMovements in defined benefitplan obligationsThese information is consistent only on anannual basis because most calculation areannualThese information is consistent only on anannual basis These information is consistent28

ITS ON SUPERVISORYREPORTING – EBA CP 50COMMENTSPROPOSALOFFREQUENCYonly on an annual basis because mostcalculation are annualThese information is consistent only on anMemo items [related to staff27.3 annual basis because most calculation areexpenses]annual28 Components of own funds - - -28.1 Subordinated financial liabilitiesMinority interests: accumulated28.2.other comprehensive income28.3Information on unrealised gainsand losses- According to IAS 1 (BC 65), the items ofthe other comprehensive income can be detailedeither net of taxes or before taxes. This optionshould not be removed because of the EBAreporting. .PROPOSALOF FIRSTREMITTANCEDATE2929.129.2Breakdown of selectedincome statement itemsRealised gains and losses onfinancial assets and liabilities notmeasured at fair value throughprofit or loss by accountingportfolioGains and losses on financialassets and liabilities designatedat fair value through profit or lossSeems to be very closed to table 17. should bedeletedIFRS 7 – (c) requires the amount of change,during the period and cumulatively, in the fairvalue of the financial asset that is attributable tochanges in the credit risk only for financial assetsThis tableshould bedeletedThis tableshould bedeleted29

29.329.4ITS ON SUPERVISORYREPORTING – EBA CP 50Gains and losses onderecognition of non-financalassets other than held for saleOther operating income andexpenses30 Related parties .Expenses and incomes30.1 generated by transactions withrelated parties30.2Key management personnelcompensation31 Scope of groupCOMMENTSor financial liabilities at fair value through profit orloss.Seems to be very closed to table 17. should bedeletedIFRSSeems to be very closed to table 17. should bedeletedSeems to be very closed to table 17. should bedeletedPart of these data is published in the annualfinancial statement. A quarterly report does not fitwith the financial statement requirements.Part of these data is published in the annualfinancial statement. A quarterly report does not fitwith the financial statement requirements .Moreover, the management key compensation isan annual data.IFRS 12 is not yet adopted by the EU . Whenadopted, this table should not ask for more thanIFRS12We already provide a similar table to our localsupervisor . This creates reporting burden.PROPOSALOFFREQUENCYThis tableshould bedeletedThis tableshould bedeletedThis tableshould bedeletedPROPOSALOF FIRSTREMITTANCEDATE30

Part II - COREPITS ON SUPERVISORY REPORTING – EBACP 50ANNEXES I et IIPART 11.2 Own fundsCOMMENTSPROPOSAL OF FREQUENCY ANDFIRST REMITTANCE DATEQuarterly – 31/03/20131.3 Own funds requirements Quarterly – 31/03/20131.4 Capital ratios Quarterly – 31/03/20131.5 Memorandum items Quarterly – 31/03/20131.5 Transitional provisions Annually – 31/12/2013PART 22 Group solvencyPART 33.2 CR SA3.3 CR IRBAnnually – 31/12/2013. Quarterly - 31/03/2013As the CRD IV will be in force at the 1st of January2013, we are focusing all our current IT developmentson this deadline. Regarding the additional data notrequired in the CRDIV project, we need at least 12months to adjust IT and reporting systems. That is why,we propose to remit the geographical breakdown in2014 and we would like to discuss the liaison of thisQuarterly - 31/03/2013 except thegeographical breakdown.31

ITS ON SUPERVISORY REPORTING – EBACP 50COMMENTSPROPOSAL OF FREQUENCY ANDFIRST REMITTANCE DATEdisclosure in relation to the FSB requirements.3.4 CR EQU IRB Quarterly – 31/03/20133.5 CR SETT Quarterly – 31/03/20133.6 CR SEC SA Quarterly – 31/03/20133.7 CR SEC IRB Quarterly - 31/03/20133.8 SEC DETAILS Annually – 31/12/2013PART 44.1 OPR Quarterly – 31/03/20134.2 OPR DETAILS Annually – 31/12/2013PART 55.1 MKR SA TDI Quarterly – 31/03/20135.2 MKR SA SEC Quarterly - 31/03/20135.3 MKR SA CTP Quarterly – 31/03/20135.4 MKR SA EQU Quarterly – 31/03/20135.5 MKR SA FX Quarterly – 31/03/20135.6 MKR SA COM Quarterly – 31/03/20135.7 MKR-IMAs the CRD IV will be in force at the 1st ofJanuary 2013, we are focusing all our current ITdevelopments on this deadline. Regarding theadditional data not required in the CRDIV project,we need at least 12 months to adjust IT andreporting systems. That is why we propose to remitthe new MKR IM with long and short positions in2014Quaterly – 31/03/201432