PRA’s position on EBA’s additional reporting

The EBA Guidelines

On 2 June 2020, the European Banking Authority (EBA) issued its Guidelines on reporting and disclosure of exposures subject to measures applied in response to the Covid-19 crisis. The Authority introduced three new templates:

• Templates One and Two relate to loans and advances subject to repayment moratoria, in accordance with the criteria set out in the EBA Guidelines on legislative and non-legislative moratoria on loan repayments applied in light of the Covid-19 crisis (EBA/GL/2020/02)
• Template Three relates to public guarantee schemes

Reminder: On 26 March and 4 June 2020, Sam Woods published two letters, ‘Covid-19: IFRS 9, Capital requirements and loan covenants’ and ‘Covid-19: IFRS 9 and capital requirements - Further guidance on initial and further payment deferrals’ setting out guidance designed to promote consistent and robust application of the definition of default in the Capital Requirements Regulation (CRR), specifically in the context of Covid-19 payment holidays, moratoria or deferrals.

The UK’s approach: Exercising proportionality options

On 24 June 2020, the PRA published a Statement, subsequently updated on 10 July 2020, in which it shared its conclusions on how it will approach the EBA Guidelines, taking into consideration the FCA and PRA approach to payment deferrals and the data the PRA already collects from UK credit institutions, in relation to payment deferrals.

The PRA noted that there is substantial benefit to disclosure-users from public information on the effects of the measures that UK firms have taken in response to Covid-19. Nevertheless, the PRA is exercising the options available in the EBA Guidelines to ensure that the disclosures are implemented in a proportionate manner, including by:

• Waiving the application of the disclosure templates for firms that are not identified as global systemically important institutions (G-SIIs) or other systemically important institutions (O-SIIs)
• Applying the disclosure templates at the highest level of consolidation in their jurisdiction

With this in mind, on 28 July 2020, the PRA published an updated Statement and set out its overall expectations on how the EBA disclosure requirements are to be implemented and how UK firms are to submit their disclosures.

The PRA mentioned that its guidance took into account the separate guidance to firms issued by the FCA ‘Mortgages and Coronavirus’ in relation to payment deferrals. A consequence of this guidance is that the form of payment moratoria or similar measures available in the UK may be broader than those specified in the EBA guidelines. So, the PRA considers that it would be appropriate for firms to make disclosures that reflect the UK approach to payment deferrals. The PRA has produced amended versions of the instructions and definitions.

Scope of institutions expected to apply the EBA Guidelines

The PRA expects that UK banks and building societies that are (or controlled by), G-SIIS or O-SIIs designated by the PRA in the most recent list, and have retail deposits equal to or greater than £50 billion on an individual or consolidated basis, should make disclosures similar to those prescribed by the EBA Guidelines, for the highest level of consolidation in the UK.

Timing

The PRA acknowledges that there may be practical difficulties caused by the publication of the EBA Guidelines and Templates, close to the 30 June 2020 disclosure reference date. The PRA realises that producing these additional disclosures to a high standard will take some time and so it will be flexible in its assessment of the timeless of the disclosure.

Therefore, the PRA does not expect relevant firms to include these disclosures in the main disclosures made for the 30 June 2020 reporting period. These can be done separately to the main Pillar 3 report. Disclosures for subsequent references dates, including 31 December 2020, should be made as part of the Pillar 3 report.

Relevant firms should make disclosures on a biannual basis. Firms may disclose as at 30 June and 31 December or may disclose at the half-year and year-end dates for their financial year, if they have an accounting reference date other than 31 December. The PRA expects firms to continue making disclosures for reporting periods ending on dates up to and including 31 December 2020.

Finally, the PRA will keep its approach to these disclosures under review for disclosure reference dates after 31 December 2020.

References

PRA Statement issued on 28 July 2020: https://www.bankofengland.co.uk/prudential-regulation/publication/2020/statement-on-covid-19-eba-guidelines-disclosure
EBA Guidelines issued on 2 June 2020: https://eba.europa.eu/eba-issues-guidelines-address-gaps-reporting-data-and-public-information-context-covid-19