22.4.2024 - Summary of minutes

Place: Microsoft Teams

Present: Officials of the Bank of Finland (BoF) and Financial Supervisory Authority (FIN-FSA). Industry representatives from ALM Partners, Aktia, the Savings Banks Group, OP Financial Group and Nordea.

1. Opening of the meeting

  • The BoF stated that the main theme for the meeting is the first version of the summary of the matching notes

    • The summary describes the matching of costs and benefits in the cost-benefit assessment (CBA) carried out in 2020–2021 and the complementary cost-benefit assessment (cCBA) carried out last year

2. First summary of the matching notes

  • The summary includes topics already discussed in the small working group but depicts a more understandable whole

  • The BoF will comment in on this first summary together with other national central banks by mid-May

    • You can have your feedback incorporated in the BoF's response by submitting it by 6 May directly to Aki Ojala (aki.ojala@bof.fi) or at BoF-IReF@bof.fi

  • Reportings combined in IReF

    • One of the objectives of IReF is to combine separate reportings into a single one.

      • AnaCredit Regulation, fulfilled by the BoF by the LuoTI data collection

      • BSI and MIR Regulations, fulfilled by the BoF by the RATI (MFI) data collection

      • SHS Regulation whose sector-specific requirements for MFIs are fulfilled by the BoF by the RATI and TIHA data collections

    • In the long term, the intention is to also incorporate supervision reports. Therefore, the objective is to keep IReF in alignment with the FINREP solo level from the start

  • Securities custody operations in the IReF

    • Since the IReF Regulation will concern banks, to put it simply, this would leave out securities custody operations pursued by some banking groups via separate companies

    • Hence, the purpose is to harmonise the requirements of the SHS Regulation with the IReF Regulation

  • Reporting agent and observed agent in IReF

    • The same concepts have also been used in AnaCredit

    • Branches whose parent is located in the euro area are observed agents, and the parent is the reporting agent

    • Branches whose parent is located outside the euro area are themselves reporting agents and observed agents

    • A monetary financial institution located in the euro area reports the data on all of its constituent observed agents, including both entities located in and outside the euro area

  • The same accounting standard is used in IReF reporting as in FINREP reporting

  • Natural persons’ loans will be reported at a loan-by-loan level but using a clearly lower number of attributes than legal persons’ loans in the current Luoti data collection. The intention is to collect the attributes required for the compilation of the BSI and MIR statistics

  • As regards protections, in the Luoti data collection, there may be more than one protection provider

  • With respect to deposits, there will be more categories, but probably not many more than in the current RATI

  • The reporting of securities will not change from the current RATI

  • Group relationships will be retrieved from FINREP table 40 and uploaded to the ECB's RIAD counterparty data system due to the locational banking statistics (LBS) requirements of the BIS

  • As a result of the cCBA, the plan to introduce a so-called event table was given up. The table would have been used to report separately data on, for example, individual issuances and interest payments

  • Hence, in practice, only stock data will be collected, and flows and revaluation adjustments will be derived in the compilation system

  • Reporting schedule

    • The reporting schedule of monthly IReF data (t + 10 working days) for the reporting entities will correspond to the current RATI

    • The second monthly data submission will take place 42 calendar days after the end of the reporting period

    • The quarterly submission will be 42 calendar days after the end of the reporting period and therefore in line with the FINREP schedule

  • In IReF, accounting data will be collected on a monthly basis on the following attributes: accounting classification of the instrument, carrying amount, prudential portfolio and accumulated impairment amount

  • Technical aspects of the data collection

    • The reporting will look largely similar to the entity relationship model in the LuoTi data collection

    • However, the file format is likely to be xBRL-CSV instead of XML

    • The change of loan identifiers will be allowed, and a uniform way to report such changes will be established for this purpose.

    • There will be a so-called Extended Technical Layer for processing national data requirements whose purpose is a uniform conceptual model and way of data collection for national requirements. Hence, going forward, national requirements will be collected in separate national add-on tables