In 2018 the SRB made a request to banks for certain data on their liabilities, as per Article 11(1) BRRD and Section B of BRRD Annex, with the aim of collecting information for drawing up and implementing resolution plans, including MREL targets. During the collection of this data, over 900 Liability Data Reports (LDRs) were requested from the 120 banking groups in scope of the exercise.
For 2019, the SRB 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 deadline of 31st March, the SRB recommends that all banks implement the following measures:
- To support high quality and complete data, the LDR report should be submitted in line with the published LDR guidance with validation checks performed by the bank ensuring reconciliation with its FINREP and COREP regulatory reporting requirements.
- 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 substantive. It is therefore of the utmost importance that the quality of and deadline for the LDR submission are respected.
The Single Resolution Board, in collaboration with National Resolution Authorities (NRAs), is embarking on its annual Liability Data Collection exercise. During the 2019 edition, the collection will be based on data as at 31 December 2018. The process will integrate lessons learned from the previous exercises and take into account the feedback received from NRAs as well as the industry.
As was the case in the 2018 data collection, the scope of the report remains unchanged and reflects the needs for resolution planning, while limiting the burden of reporting for the groups and entities. Nevertheless, the SRB retains the flexibility to request additional information wherever and whenever it deems necessary to do so.
(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.
Depending on the IT facilities and the individual process for the data collection, NRAs may decide to restrict the format that institutions can submit (i.e. purely Excel or XBRL). Institutions should contact their NRA via the established channels to learn more about the process for the data collection in their jurisdictions. Below are the 2019 LDR Template (Excel) and associated Guidance for the data to be reported by banks.
- 2019 Draft Guidance on the Liability Data Report v2.3_track_changes
- 2019 Draft Guidance on the Liability Data Report v2.3clean
- Liability Data Reporting 2019 v2.7.1
Insolvency regimes of Member States within the Banking Union are currently being analyzed for changes in order to provide an updated mapping for each jurisdiction. The most recent updates to this document are available below:
The SRB provides institutions with a data Validation Tool. This tool enables those institutions reporting in Excel to perform initial data checks, identical to the XBRL validation rules listed below, prior to delivering the reports to their NRAs. In so doing, this should reduce the risk of errors in the reports upon conversion to XBRL by the SRM.
Alignment with EBA Implementing Technical Standards on Resolution Reporting
On September 30th 2018 the SRB published the final version of its framework for the 2019 Liability Data Report (LDR) data collection process. Both the 2019 LDR template and the related taxonomy have been elaborated in collaboration with the EBA in an effort to reduce the burden on banks under SRB remit for reporting of liability data in resolution reporting. The EBA Implementing Technical Standard (ITS) were published on April 17th 2018 and updated August 9th 2018.
Shared Scope of Reporting Requirements
In an effort to reduce the reporting burden on banks, the SRB has adapted part of its 2019 LDR such that it covers the EBA’s minimum requirements for Liability reporting:
- SRB T01.00 = EBA Z 02. LIAB
- SRB T02.00 = EBA Z 03. OWN
This means that for banks under its remit, the SRB (via NRAs) will collect these shared templates and communicate them to the EBA.
SRB-specific reporting elements
To facilitate the data collection needs that are specific to the SRB’s mandate, the Liability Data Report contains additional data fields (SRB T03.01 to SRB T08.00). From an XBRL taxonomy perspective, these data points were already reflected in the EBA ITS publication in April 2018.
SRB Taxonomy extension
The SRB’s taxonomy publication represents an SRB extension to the EBA ITS. This extension contains minor changes to the taxonomy and validation rules which the SRB deems necessary to facilitate the data collection in XBRL format in 2019:
- Expand the current (single) EBA entry point (RESOL) to the 4 SRB entry points (CON, RES, INDOTH, INDPOE);
- Improve data quality by expanding the list of Validation rules (ldr_v0073 to ldr_v0100).
SRB Taxonomy extension documents:
In respect of timing, the deadline for submission of the reports is 31st March 2019 for all institutions.
Frequently Asked Questions
Questions on the LDR can be raised directly with the SRB via LDR-QnA@srb.europa.eu from October 1st until December 15th 2018. Feedback will be provided by an updated FAQ (see below). After December 15th, questions can still be raised but via each institution’s NRA. The final version of the 2019 LDR Guidance will be published end December 2018, incorporating feedback received during the Q&A.
Note that any updates to the XBRL and other LDR-related documentation will be provided on this page.
Timeline for the 2019 LDT data collection process