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    EBA Publishes Standards on Disclosure and Reporting of MREL and TLAC

    August 03, 2020

    EBA published the final draft implementing technical standards for disclosures and reporting on the minimum requirements for own funds and eligible liabilities (MREL) and the total loss-absorbing capacity (TLAC) requirements in EU. The draft technical standards include templates and tables implementing the TLAC and MREL Pillar 3 disclosure and supervisory reporting requirements. The technical package accompanying the reporting requirements and including the Data Point Model (DPM), validation rules, and XBRL taxonomy is expected to be published in the third quarter of 2020 and will be a part of the EBA reporting framework 3.0. The final draft technical standards will be submitted to EC for endorsement.

    EBA has prepared these draft technical standards following the mandates in the revised Capital Requirements Regulation (CRR 2) and Bank Recovery and Resolution Directive (BRRD 2). The provisions of the technical standards on disclosures on TLAC are to apply immediately after their adoption by EC and entry into force. In contrast, the provisions on disclosures on MREL will apply from the date of expiration of the relevant transition periods pursuant to Article 45m of BRRD (2014/59/EU)—that is from January 01, 2024 or, where the resolution authority has set a compliance deadline after January 01, 2024, from that compliance deadline. The first reference date for reporting in accordance with these implementing technical standards is expected to be June 30, 2021 (as part of the reporting framework 3.0) for reporting on both the MREL and TLAC requirements. The expected implementation period for the proposed reporting requirements is nine months to one year. The disclosure and reporting requirements on TLAC apply only to global systemically important institutions (G-SIIs), entities that are part of G-SIIs, and material subsidiaries of non-EU G-SIIs. The disclosure and reporting requirements on MREL apply to entities other than those whose resolution plan provides that they would be wound up under normal insolvency proceedings.

    EBA sought to maximize efficiency for entities when complying with their disclosure and reporting obligations and to facilitate the use of information by authorities and market participants. For these purposes, MREL and TLAC are presented in an integrated manner, both in the reporting and disclosure templates. The reporting and disclosure requirements have been enshrined in a single set of implementing technical standards. The quantitative information that has to be disclosed is integrated with supervisory reporting data and a mapping table linking the two has been provided. The approach followed seeks to maximize the consistency and comparability of disclosures, to reinforce the Pillar 3 objective of market discipline, with common templates and definitions developed in alignment with the relevant BCBS Pillar 3 standards. The annexes to final report on draft implementing standards include the information on:

    • Templates (Annex 1) and instructions (Annex 2) for MREL and TLAC reporting
    • Planned data point model and validation rule requirements (Annex 3)
    • Standardized ranking of instruments and items for reporting on MREL and TLAC (Annex 4)
    • Templates (Annex 5) and associated instructions (Annex 6) for MREL and TLAC disclosures

    EBA had published, in November 2019, the proposals implementing the disclosure and reporting requirements on MREL and TLAC and the proposals on two reporting templates covering forecast MREL and TLAC positions and funding structures. Although these final draft standards address the disclosure and reporting requirements on MREL and TLAC, the proposals on two reporting templates covering forecast MREL and TLAC positions and funding structures are not part of these final draft implementing standards.


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    Keywords: Europe, EU, Banking, MREL, TLAC, Reporting, Disclosures, Pillar 3, Basel, CRR2, BRRD2, Implementing Technical Standards, G-SII, EBA

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