[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-247064-105":53,"doc-detail-247064-en":126},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":119,"head_meta":121,"extra_data":123,"updated_unix":125},105,"en","eba-reporting-simplification-module-9-other-changes","EBA Reporting Simplification - Module 9 - Other Changes","","Consultation responses for EBA reporting simplification focus on Module 9 “Other Changes” (July 2026). The document assesses the clarity of leverage ratio templates and recommends removing LR1 alongside the already welcomed removal of LR4. It proposes adjusting Pillar 3 disclosure tables by deleting only RWA-related columns while retaining leverage exposure columns. For COREP leverage ratio changes, it finds no disproportionate compliance cost. It also supports simplification of cash pooling reporting to reduce operational burden and addresses shadow banking templates by calling for materiality thresholds and revising low reporting thresholds for large institutions.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":11,"@type":70,"position":76},"https://docshare.wps.com/template/presentations/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/eba-reporting-simplification-module-9-other-changes/247064/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/eba-reporting-simplification-module-9-other-changes/247064.png","ImageObject",442,249,{"name":88,"@type":89},"Fez","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-22","2026-09-12",true,{"@type":98,"interactionType":99,"userInteractionCount":47},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"How are leverage ratio templates assessed for clarity and consistency?","Question",{"text":108,"@type":109},"Leverage ratio templates are considered sufficiently clear because they are embedded in existing processes. Template C_43 is used for Pillar 3 LR3 semi-annual disclosure via the EBA mapping tool and also supports quarterly consistency checks with Credit Risk and template C 08.07.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"Which template removals are supported, and what additional deletion is proposed?",{"text":113,"@type":109},"The removal of template LR4 is welcomed. The response also does not see the need for LR1 under the leverage ratio rules and proposes removing LR1 as well.",{"name":115,"@type":106,"acceptedAnswer":116},"What changes are suggested to reduce operational effort in shadow banking reporting?",{"text":117,"@type":109},"The response urges adding a materiality or reporting threshold for scoping exposures because the proposed template lacks one. It also calls for removing or significantly increasing the low EUR 300 million threshold used for the 10 largest shadow banking exposures for large institutions, suggesting a relative threshold based on Tier 1 capital.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},247064,1791746291,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":8,"category_name":11,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":47,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":135,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":76},2336478940794,"https://ap-avatar.wpscdn.com/davatar_9964176cb1d06d4a9deccf72a44ae3dc","Consultation Response  \nEBA Reporting Simplification: Module 9 – Other Changes  \nJuly 2026  \nConsultation Questions  \nQuestion 1. Are the instructions and templates clear to the respondents?  \nLeverage ratio Templates can, in general, be considered sufficiently clear, as they are already integrated into existing processes. Template C_43 is used as an input for the Pillar 3 LR3 semi-annual disclosure according to the EBA mapping tool and is also used on a quarterly basis for consistency checks with Credit Risk and with template C 08.07, which follows leverage ratio metrics under Article 429 CRR.  \nQuestion 2. Do the respondents identify any discrepancies between these templates and instructions and the calculation of the requirements set out in the underlying regulation?  \nWhile the removal of template LR4 is welcome, we also don't see the need for LR1 in light of the underlying regulation for leverage ratio, and propose that LR1 is also removed.  \nNo specific discrepancies are identified. Leverage ratio templates are already aligned with leverage ratio metrics under Article 429 CRR; Template C_43 is used for consistency checks with Credit Risk and C 08.07. Unless it is intention of the Regulator to delete Table LR3 in Pillar 3 disclosure amending related EBA mapping tool with Template C_43 (possibility not recalled in the CP EBA), we suggest deleting only columns related to RWAs (columns c0030 and c0040) and maintaining columns related to the Leverage Exposure (columns c0010 and c0020), which also act as a check with Template C_47.  \nQuestion 3. Cost of compliance with the reporting requirements: Is or are there any element(s) of this proposal for new and amended reporting requirements that you expect to trigger a particularly high, or in your view disproportionate, effort or cost of compliance? If yes, please:  \n• specify which element(s) of the proposal trigger(s) that particularly high cost of compliance,  \n• explain the nature/source of the cost (i.e. explain what makes it costly to comply with this particular element of the proposal) and specify whether the cost arises as part of the implementation, or as part of the on-going compliance with the reporting requirements,  \n• offer suggestions on alternative ways to achieve the same/a similar result with lower cost of compliance for you.  \nFor COREP Leverage ratio proposals only, we see:  \n• No particularly high or disproportionate cost elements are identified.  \n• No significant additional implementation or ongoing costs are expected;  \n• The template is already embedded in existing reporting and control frameworks  \nQuestion 4. Is the deletion of rows in template C 47.00 of Leverage ratio reporting, related to cash pool arrangement, cost reducing to institutions?  \nWe welcome the proposed simplification measures, in particular the reduction in reporting frequency for certain templates from quarterly to annual reporting, the removal of template C 43, and the simplification of cash pooling reporting requirements.  \nThese changes are expected to generate tangible operational benefits for some banks by reducing reporting effort, implementation costs and ongoing maintenance requirements. In our view, several of the affected templates were largely redundant, providing limited additional supervisory value while requiring complex reporting developments and controls.  \nFurthermore, the information reported in these templates does not generally have a direct impact on prudential ratios or key supervisory metrics. Therefore, their simplification or removal represents a proportionate measure that reduces operational burden without materially affecting supervisory oversight.  \n2.2.1. Aggregate exposure to shadow banking entities (C 37.00)  \nOn Shadow Banking Aggregate Exposure Template (C 37.00):  \nWe acknowledge the CRR3 mandate under Article 394(2) requiring institutions to report aggregate exposures to shadow banking entities (Module 9, Section 1.1, paragraphs 3–15). We support the ","cbCaieLyGgsgvBxG","https://ap.wps.com/l/cbCaieLyGgsgvBxG","pdf",321275,8,"English","# Consultation Questions\n## Question 1: Clarity of instructions and templates\n## Question 2: Discrepancies with underlying regulation\n## Question 3: Cost of compliance considerations\n## Question 4: Deletion of rows in template C 47.00 (cash pooling)\n## Aggregate exposure to shadow banking entities (C 37.00)\n### Large Exposures reporting thresholds\n### Counterparty identifiers in large exposure reporting","[{\"question\":\"How are leverage ratio templates assessed for clarity and consistency?\",\"answer\":\"Leverage ratio templates are considered sufficiently clear because they are embedded in existing processes. Template C_43 is used for Pillar 3 LR3 semi-annual disclosure via the EBA mapping tool and also supports quarterly consistency checks with Credit Risk and template C 08.07.\"},{\"question\":\"Which template removals are supported, and what additional deletion is proposed?\",\"answer\":\"The removal of template LR4 is welcomed. The response also does not see the need for LR1 under the leverage ratio rules and proposes removing LR1 as well.\"},{\"question\":\"What changes are suggested to reduce operational effort in shadow banking reporting?\",\"answer\":\"The response urges adding a materiality or reporting threshold for scoping exposures because the proposed template lacks one. It also calls for removing or significantly increasing the low EUR 300 million threshold used for the 10 largest shadow banking exposures for large institutions, suggesting a relative threshold based on Tier 1 capital.\"}]","EBA Reporting Simplification - Module 9 - Other Changes | PDF",1789239777]