EBA · 2023_6841 Rejected question

Disclosure requirements for non-complex and non-listed institutions

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
433b, para. 1, 2
Topic
Transparency and Pillar 3
Submitted by
Credit institution
Submitted
2023-07-17
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Question

We would appreciate clarification regarding disclosure requirements by institutions detailed in Part 8 of CRR 575/2013, more precisely Article 433b, paragraphs (1) and (2). Should non-listed small and non-complex institutions disclose paragraphs 1, points (a) and (b) on an annual basis or what should they consider to be correct, key metrics from article 447 also on an annual basis?

Background

Our interpretation of the Article 433b, paragraph 2 which states “By way of derogation from paragraph 1 of this Article, small and non-complex institutions that are non-listed institutions shall disclose the key metrics referred to in Article 447 on an annual basis.“ is such that non-listed small and non complex institutions are not obliged to disclose requirements which are stated in paragraph 1, point (a) of the Article 433b of CRR 575/2013. Our reasoning is in the formulation of paragraph 2 which clearly states “By way of derogation from paragraph 1 of this Article…“, meaning that paragraph 2 completely derogates paragraph 1 and not only paragraph 1, point (a), therefore requests only the disclosure of the key metrics referred to in Article 447 on an annual basis which are stated in paragraph 2.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2023_6841

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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