2020 Resolution Reporting

In 2019 the SRB made a request to banks for resolution reports[1] with the aim of collecting information for drawing up and implementing resolution plans, including calibrating Minimum Requirement for own funds and Eligible Liabilities (MREL) targets. During the collection of this data, Resolution Reports were requested from the 120 banking groups in scope of the exercise.

For 2020, the SRB once again highlights the importance of high quality, complete and timely data submissions. The ability to provide the necessary data to support the implementation of the resolution strategy, is a key resolvability issue, to be adequately considered by banks’ top management. To ensure banks meet the reporting deadlines (see timeline below), the SRB recommends that all banks implement the following measures:

  1. To support high quality and complete data, the resolution reports should be submitted in line with the published guidance, with validation checks performed by the bank ensuring reconciliation with its FINREP and COREP regulatory reporting requirements (where applicable – see Guidance documents below).
  2. Banks should ensure that they have the necessary IT processes in place to facilitate a timely, controlled and robust reporting process generating consistent and reliable results.

Data quality and availability on time are key items to consider within the resolvability assessment. In this context, the SRB can consider the failure to comply with the information requirements as impediments to resolvability, potentially significant. It is therefore important that the quality of and deadlines for the resolution reporting submissions are respected.

The SRB, in collaboration with the National Resolution Authorities (NRAs), is starting its annual Resolution Reporting Data Collection exercise. During the 2020 edition, the collection will be based on data as at 31 December 2019. The process will integrate lessons learned from the previous exercises and take into account the feedback received from NRAs as well as the industry.

The scope of the reports has evolved to reflect the needs for resolution planning, while limiting the burden of reporting for the banks. Nevertheless, the SRB retains the flexibility to request additional information wherever and whenever it deems necessary to do so.

As concerns the reporting perimeters, (Sub)-Consolidated views are based on the prudential scopes of consolidation, whereas Resolution Groups are to be defined by Internal Resolution Teams, in collaboration with the respective institutions.

Overview of SRB Resolution Reporting Requirements for 2020

The SRB is responsible for centralising resolution reporting for banks under its remit, before these are transferred to the European Banking Authority (EBA). To reduce the burden on banks, where there is an overlap between the EBA and the SRB reporting requirement, this has been highlighted.

Note that the reports listed below will be collected by the SRB from NRAs exclusively in XBRL format. As was the case in previous collections, NRAs will communicate banks’ reporting requirements, as determined in collaboration with the SRB.

 

EBA Template numberEBA Template codeName of the template or group of templatesEBA Short nameSRB Replacement ReportSRB ReferenceReporting deadline
  ENTITY INFORMATION, GROUP STRUCTURE, CONTACTS AND DEPENDENCIES    
1Z 01.00Organisational structureORGN/AN/A30/04/2020
  INFORMATION ON ON- AND OFF-BALANCE SHEET ITEMS    
2Z 02.00Liability StructureLIABLDRT 01.0031/03/2020
3Z 03.00Own funds requirementsOWNLDRT 02.0031/03/2020
4Z 04.00Intragroup financial connectednessIFCLDRT 03.01-.0331/03/2020
5.1Z 05.01Major counterparties (Liabilities)MCP 1N/AN/A30/04/2020
5.2Z 05.02Major counterparties (off-balance sheet)MCP 2LDRT 12.0031/03/2020
6Z 06.00Deposit insuranceDISN/AN/A30/04/2020
  CORE BUSINESS LINES, CRITICAL FUNCTIONS AND RELATED INFORMATION SYSTEMS AND FINANCIAL MARKET INFRASTRUCTURES    
  Critical functions and core business lines    
7.1Z 07.01Criticality assessment of economic functionsFUNC 1CFT 20.01-.05,  T 98.0030/04/2020
7.2Z 07.02Mapping of critical functions to legal entitiesFUNC 2N/AN/A30/04/2020
7.3Z 07.03Mapping of core business lines to legal entitiesFUNC 3N/AN/A30/04/2020
7.4Z 07.04Mapping of critical functions to core business linesFUNC 4N/AN/A30/04/2020
8Z 08.00Critical servicesSERVN/AN/A30/04/2020
  FMI services - providers and users    
9Z 09.00Users, providers and users - mapping to critical functionsFMI 1FMIT 30.00-T33.0030/04/2020
  Information systems    
10.1Z 10.01Critical Information systems (General information)CIS 1N/AN/A30/04/2020
10.2Z 10.02Mapping of information systemsCIS 2N/AN/A30/04/2020
  OTHER SRB REPORTING TEMPLATES (included in EBA 2.9 Reporting Framework)    
  Liability Data Report    
N/AN/AIdentification of the reportN/ALDRT 99.0031/03/2020
N/AN/ASecurities (Including CET1, AT1 & Tier 2 Instruments; Excluding intragroup)N/ALDRT 04.0031/03/2020
N/AN/AAll Deposits (excluding intragroup)N/ALDRT 05.0131/03/2020
N/AN/AOther financial Liabilities (not included in other tabs, excluding intragroup)N/ALDRT 06.0131/03/2020
N/AN/ADerivativesN/ALDRT 07.0031/03/2020
N/AN/ASecured Finance, excluding intragroupN/ALDRT 08.0031/03/2020
N/AN/AOther Non-Financial (not included in other tabs, excluding intragroup)N/ALDRT 09.0031/03/2020


Where an SRB Replacement Report exists (e.g. Z 02.00 is replaced by T 01.00), ONLY the replacement report should be sent by the bank (T 01.00).

Where no SRB Replacement Report exists (e.g. Z 10.01), then the Z report needs to be sent (if requested by the NRA/SRB from the reporting entity).

With the exception of T99.00, the "Other SRB Liability templates" should only be filled when explicitly requested by the NRA/SRB (granular reporting of POE files).

The reporting deadline for the LDR is 31/03/2020; for all other reports 30/04/2020.

Below are links to the Guidance documents for SRB-originated resolution reports:

 

SRB Taxonomy Extension

The SRB’s taxonomy publication represents an SRB extension to the EBA 2.9 ITS. This extension contains minor changes to the EBA taxonomy and validation rules which the SRB deems necessary to facilitate the data collection in XBRL format in 2020:

  • Expand the current EBA two entry points (RESOL_CON and RESOL_IND) to the 5 SRB entry points for LDR (LDTCON, LDTRES, LDTINDOTH, LDTINDPOE, LDTCONPOE), 4 entry points for CFR (CFRCON, CFRRES, CFRIND, CFRCONPOE), 2 entry points for CIR (CIRCON, CIRIND) and one entry point for FMIR (FMICON);
  • Improve data quality and data collection efficiency by expanding the list of Validation rules and modifying certain existing validation rules.

 

SRB Taxonomy extension documents:

 

SRB Taxonomy extension – sample XBRL instances:

The XBRL instances are provided as examples and fulfil the XBRL2.1 specification and ResRep 4.0.3 taxonomy (which is an extension of EBA2.9).

These files pass the Level 1 & Level 2 data validations but have not been configured to pass the Level 3 checks described in the Guidance documents.

All values stored in the XBRL facts are fictitious.

 

Additional Liability Data Collection (Reporting in Excel format)

In addition to the Commission Implementing Regulation 2018/1624 minimum requirements and SRB-specific reports outlined above, the SRB has decided to anticipate ongoing work with the EBA on MREL reporting  following changes to the Banking Package, and to revise the template for MPE data collection.

The revised MPE template anticipates the proposed MPE methodology. This data request will not pre-empt the orientation on the MPE policy: this data request is inherent to the build-up of the policy, and has been designed to ensure the timely collection of data by March 2020.

The data request for the Additional Liability Report is be reflected in a dedicated reporting template and related Guidance to be used for the 2020 data collection:

 

Timeline for the 2020 Resolution Reporting data collection process

 

*Banks are expected to reflect both the EBA 2.9 XBRL taxonomy (available on the EBA website) and the SRB taxonomy extension (published on the SRB website) when building their XBRL reporting systems for 2020.

**QnA organised by SRB will be limited to questions on SRB-originated reports (LDR, CFR, FMIR). Questions on other CIR reporting requirements should be raised with the EBA.

***CIR – Commission Implementing Regulation 2018/1624

[1] As per Article 11(1) BRRD and Section B of BRRD Annex

 

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Contact the Single Resolution Board

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Belgium

+32 (0) 2 490 30 00