Circular BCL 2014/235 of 20 January 2014 — Modification of statistical data collection from credit institutions

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Luxembourg, 20 January 2014
To all credit institutions

CIRCULAR BCL 2014/235
Modification of statistical data collection from credit institutions

Madam, Sir,

On 24 September 2013, the Governing Council of the European Central Bank (ECB) adopted ECB Regulations 2013/33 concerning the balance sheet of the monetary financial institutions sector (recast) and ECB/2013/34 concerning statistics on interest rates applied by monetary financial institutions (recast). These regulations, published in the Official Journal of the European Union on 7 November 2013, complement the existing framework of ECB statistical activities necessary to enable the European System of Central Banks (ESCB) to perform its functions by defining the natural and legal persons subject to reporting obligations, the confidentiality regime, and adequate implementation and sanction provisions, in accordance with Article 5.4 of the Statutes of the ESCB and the ECB.

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All ECB requirements for statistical reporting by credit institutions adhere to three essential rules.

First, the ECB must receive comparable, reliable, and up-to-date statistical information, collected under similar conditions throughout the euro area.

Second, the reporting obligations set out in the regulations must respect the principles of transparency and legal certainty. The regulations are therefore binding and apply directly throughout the euro area. They impose direct obligations on legal or natural persons, subject to sanctions that may be imposed by the ECB if reporting requirements are not met.

The statistical information subject to reporting, in accordance with ECB requirements, and the minimum standards to be respected are detailed in the aforementioned ECB regulations.

In accordance with ECB Regulations 2013/33 and 2013/34, National Central Banks (NCBs):

• determine and implement the reporting framework to be followed by the actual reporting population in accordance with national characteristics;
• exercise the right of verification or mandatory collection of information that reporting agents are required to provide, pursuant to the aforementioned ECB regulation.

Based on the aforementioned ECB regulations, the Banque centrale du Luxembourg (BCL) has developed a data collection system for credit institutions, the characteristics of which are detailed in this circular.

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1 Objectives

The data collection system, developed by the BCL based on the aforementioned ECB Regulations 2013/33 and 2013/34, is intended to meet the following objectives:

• complete coverage of the foreseeable ECB requirements for monetary and financial statistics;
• complete coverage of the needs expressed by the various BCL units as well as the needs expressed by the National Institute of Statistics and Economic Studies (STATEC) to cover information needs in the field of financial and non-financial national accounts;
• minimization of the workload for reporting agents;
• consistency with data collected for prudential supervision purposes. This consistency, which is not possible for all information to be collected, allows the use of prudential data in the process of compiling data for the ECB and contributes to the quality control of collected data;
• compatibility with the ESA 2010 standard (European System of Accounts 2010). The conformity of data collected according to the ESA 2010 standard will facilitate their use in the field of national accounting and in the field of the balance of payments and should help avoid additional surveys.

2 Main Innovations

Compared to the existing statistical data collection system, the main innovations are manifested at several levels:

• the update, and even modification, of the code nomenclature used in the context of statistical reporting;
• the introduction of a new statistical report;
• the modification of existing statistical reports;
• the update of the statistical report nomenclature.

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2.1 Update of the code nomenclature used in the context of statistical reporting

The update of the sector code nomenclature proved indispensable following the introduction of a new version of the European System of Accounts; indeed, from 2014 onwards, national accounting will abandon ESA 95 to comply with ESA 2010. This update affects all statistical reports requiring a breakdown by economic sector based on the counterparty of activities; these are the following reports:

• S 1.1 "Monthly statistical balance sheet of credit institutions"
• S 1.4 "Valuation effects on the balance sheet of credit institutions"
• S 1.5 "Interest rates in EUR"
• S 1.8 "Securitizations and other transfers of claims by credit institutions"
• TPTBBL Title-by-title report – Balance sheet data
• TPTBBN Title-by-title report – Balance sheet data
• TPTBHR Title-by-title report – Off-balance sheet data – Resident clients
• TPTBHN Title-by-title report – Off-balance sheet data – Non-resident clients
• S 2.5-L "Quarterly statistical balance sheet of credit institutions"
• S 2.5-N "Quarterly statistical balance sheet of credit institutions"
• S 3.2 "Non-balance sheet information"

In this context, we have also adapted the nomenclature related to the breakdown by instrument, maturity, and rate fixation period to update it, make it more flexible, and more intuitive in its use.

Finally, it is understood that the new statistical reports to be introduced in 2014 are also based on this new nomenclature.

2.2 New statistical report

In the context of the overhaul of statistical data collection, the title-by-title report in accounting version N (TPTBBN) will be introduced. This is a title-by-title report that includes, in addition to the securities held and issued by local banks, also the details of securities held by their branches.

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2.3 Modification of existing statistical reports

The majority of statistical reports have undergone more or less pronounced modifications following the introduction of the ESA 2010 version of the European System of Accounts.

The major modifications can be summarized as follows:

• the addition of new information, for example on credit commitments granted as well as guarantees granted, on reports S 1.1 "Monthly statistical balance sheet of credit institutions" and S 2.5 "Quarterly statistical balance sheet of credit institutions" (S 2.5-L and S 2.5-N);
• the addition of additional information, for example on credit renegotiations, on report S 1.5 "Interest rates in EUR";
• the addition of supplementary information on report S 1.8 "Securitizations and other transfers of claims by credit institutions";
• the increase in the frequency of report S 4.1 "Non-balance sheet information" (renamed S 3.2) and the addition of information concerning the loan-to-value ratio and the number of accounts.

With regard specifically to report S 2.9 "Staff numbers", a complete overhaul is necessary; thus, the report in question has been entirely reviewed to better reflect the realities of the contemporary working world.

2.4 Update of the statistical report nomenclature

In the context of data collection, credit institutions submit reports containing information on their balance sheet (accounting version L) and reports containing information on the aggregated balance sheet of Luxembourg entities and their branches abroad (accounting version N).

In this context, we have opted for a new approach that will no longer distinguish statistical reports by accounting version; indeed, we have decided to abandon the concept of accounting version for statistical reports and to create, for each accounting version, a different statistical report.

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Thus, rather than distinguishing report S 2.5 in accounting versions L and N, the chosen solution will be as follows:

• report S 2.5 accounting version L will remain as report S 2.5-L;
• report S 2.5 accounting version N will become report S 2.5-N.

The same applies to the title-by-title report, for which we will have the following situation:

• report TPTBBS will become report TPTBBL;
• the new report TPTBBS in accounting version N will be report TPTBBN.

In this context, we wish to emphasize that this modification of the nomenclature does not call into question the principle of parallelism of these reports; thus, as an example, reports S 2.5-L and S 2.5-N are perfectly identical but the information requested is to be established either for the Luxembourg entity (S 2.5-L) or for the set formed by the Luxembourg entity and its branches abroad (S 2.5-N).

Finally, the following reports will also be renamed:

• report S 2.9 accounting version L will become report S 2.9-L;
• report S 2.9 accounting version N will become report S 2.9-N;
• report TPTBOB will become report TPTBHR;
• report TPTBNR will become report TPTBHN;
• following an increase in reporting frequency, report S 4.1 will become report S 3.2.

3 Integration of new ECB requirements into BCL statistical data collection

Insofar as the requested modifications do not fundamentally call into question the current architecture of the reports:

• S 1.1 "Monthly statistical balance sheet of credit institutions"
• S 1.4 "Valuation effects on the balance sheet of credit institutions"
• S 2.5 "Quarterly statistical balance sheet of credit institutions",

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it was decided to maintain the existing tables while incorporating the aforementioned additional information.

However, for the following reports:

• S 1.5 "Interest rates in EUR"
• S 1.8 "Securitizations and other transfers of claims by credit institutions"
• S 2.9 "Staff numbers"
• S 3.2 "Non-balance sheet information",
  a modification of the report structure proved indispensable to integrate all new requests.

4 BCL statistical reporting

Based on the information presented above, the statistical reporting that credit institutions must periodically submit to the BCL now includes the following reports:

• S 0.1 "Daily deposit report"
• S 1.1 "Monthly statistical balance sheet of credit institutions"
• S 1.4 "Valuation effects on the balance sheet of credit institutions"
• S 1.5 "Interest rates in EUR"
• S 1.8 "Securitizations and other transfers of claims by credit institutions"
• Title-by-title report – Balance sheet information (TPTBBL and TPTBBN)
• Title-by-title report – Information on assets held for third-party accounts (TPTBHR and TPTBHN)
• S 2.5 "Quarterly statistical balance sheet of credit institutions" (S 2.5-L and S 2.5-N)
• S 2.8 "Real estate loans granted for buildings located in Luxembourg"
• S 2.9 "Staff numbers" (S 2.9-L and S 2.9-N)
• S 3.2 "Non-balance sheet information"

In this context, we wish to remind reporting agents that they are required to provide a copy of BCL reports to the CSSF.

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Finally, it should be noted that all instructions for the preparation of statistical reporting are published and can be downloaded from the BCL website at the following addresses:
http://www.bcl.lu/fr/reporting/Etablissements_de_credit/index.html http://www.bcl.lu/en/reporting/credit_institutions/index.html

5 Quality of transmitted data

It is important to emphasize the quality of data transmitted to the BCL and the necessity of subjecting this data to the verification rules detailed in the technical documentation before transmission. Only rigorous control performed at the time of data production can meet both quality requirements and imposed deadlines. This point is all the more important as the data collected in this manner are controlled by ECB services before being aggregated with data from other Member States. Any significant error or negligence would have damaging repercussions on the reputation of the entire Luxembourg financial community.

6 Compliance with reporting deadlines

The BCL will establish and publish on its website a table listing the precise deadlines by which statistical tables must be submitted.

Credit institutions are reminded that the BCL must transmit monthly and quarterly statistical reports to the ECB within respective deadlines of 15 and 28 working days following the period to which they relate. It is therefore essential that institutions strictly respect the defined delivery deadlines so that the BCL can meet its commitments within the framework of the ESCB.

7 Implementation of the new collection

The provision of this information is mandatory starting from the December 2014 deadline; the first reports are therefore those relating to the end of December 2014.

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8 Test phase

Credit institutions that wish to do so can participate in a test phase starting in September 2014. Monthly submissions can be made from September 2014 for the reference period of August 2014. Quarterly submissions will be possible from October 2014 for the reference period of the third quarter of 2014.

The BCL will inform credit institutions of the results of these tests and request, if necessary, that the entities concerned carry out additional test submissions to eliminate any remaining quality issues.

Please accept, Madam, Sir, the assurance of our most distinguished sentiments.

BANQUE CENTRALE DU LUXEMBOURG

Pierre BECK Serge KOLB Gaston Reinesch
General Director