Disclosures and Regulatory reporting

Under Basel 3.1, firms are classified based on a range of criteria, such as retail deposits, total assets, derivatives, complexity, or processes.

As a result, they will fall into one of the following categories:

  • large institutions
  • small and non-complex institutions (listed/ non-listed)
  • other institutions (listed/ non-listed)

The firm’s classification influences the frequency in which it must submit disclosures. These disclosures will be made on an annual, semi-annual, or quarterly basis.

Reporting Template Changes

The PRA proposes modifications to 12 existing COREP templates and three Capital+ templates. They also intend to introduce a further 19 new COREP templates. The PRA is making these changes with the intention of reducing the risk of inadequate capital reporting.

Credit risk templates have been amended to reflect the new conversion factors and the new granularity of increased risk weights in the proposed standard approach requirements.

Three operational risk templates have been disbanded. The PRA is introducing a new template which reflects the revisions made to the calculation of operation risk. This template will cover: the PRA approval cover sheet, minimum required capital report, breakdown of business indicator components to be reported as per IFRS or national GAAP definitions and historical losses and internal loss multiplier (ILM).

The PRA has proposed seven new market risk templates. This is inclusive of general interest rate risk, credit spread risk for non-securitisations, credit spread risk for securitisation included in the alternative correlation trading portfolio, credit spread risk for securitisation not included in the alternative correlation trading portfolio, equity risk, commodity risk, foreign exchange risk. Here the focus is on moving towards a greater degree of granularity in identifying risk through disclosures and increasing transparency for firms’ investors. Under market risk, there will be new templates for default risk capital risk capital requirement, advanced standardised approach (ASA) residual risk add-on, equity investment in funds and authorisations. 

What banks should consider:

  • Data: The new reporting and disclosure requirements are more granular and descriptive in nature. Firms will be required to collect and comment on data continuously between reporting periods. Qualitative narratives on processes and transitional provisions will need to be drafted and stored before a regulatory due date. There is also an additional focus on the compilation of historical data. Transitional and historical data management will require additional firm resources due to the increased frequency of collecting, reviewing and analysing information for the additional, more detailed disclosure and reporting templates. The data provided must indicate to the regulator that risk provisions align with risk management and mitigation strategies.
  • Geographies: Different jurisdictions may adopt varying approaches leading to inconsistencies in regulatory standards. Firms will need to ensure that across geographies financial controllers’ procedures reconcile and that their internal financial mapping is both consistent but also compliant with relevant domestic expectations.
  • Internal Controls & Resourcing: Due to the increase and amendments of reporting templates, firms may need to alter their reporting approach and strategic controls to reflect the granular nature of the new guidance. This may require additional staff members, checks, training, or implementation of new software packages/processes.
  • Cost: Successful implementation of the new framework and interpretation of the templates will require significant investments in infrastructure, technology, and human resources. If the firm does not consider or implement appropriate planning for this regulation, it may cause delays in publishing their Annual/Bi-Annual Reports potentially resulting in regulatory censure.

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