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Letters

Response to submissions - proposed changes to ADI quarterly reporting due dates

Tuesday 11 May 2021

Published 11 May 2021

The Australian Prudential Regulatory Authority (APRA) has today released a response to submissions on proposed changes to the due dates for ADI quarterly reporting.

Background

In November 2019, APRA consulted on a proposal to standardise quarterly reporting due dates for ADIs to 35 calendar days after the last day of the reference quarter. 

Different quarterly reporting forms are due 15, 20, and 30 business days and 28 calendar days after the end of the quarter. A shift to 35 calendar days extends the time ADIs have to submit data for forms previously due on 15 or 20 business days or 28 calendar days. However, for forms with a due date of 30 business days after the end of the quarter, this reduces the submission timeframe.

On the 1st of April 2020, APRA granted an extension of the due dates for all quarterly forms that were due before 35 calendar days to calendar day 35 as part of a package of COVID relief considerations.1

Submissions received

APRA received four submissions – two from industry bodies, and two from reporting entities. Submissions were very supportive of the standardisation of reporting due dates, however they raised concerns regarding lower quality of data submitted due to compressed time frames; and potential market sensitivity of the data. One submission recommended the retained use of business days. 

Impacts of bringing forward the due date for ADIs

Two submissions raised concerns that the proposed initiative would reduce the timeframe to submit a small number of forms.  Concerns were focused on the data submitted potentially being of a poorer quality or may have not been approved by boards. Further, there were concerns raised that by bringing forward dates, the data may become market sensitive.

APRA understands that standardising due dates may impose initial complications on ADIs. However, APRA’s view is that, as the complete standardisation will be staggered for forms where there will be a reduction in the submission timeframe, ADIs will have ample time to ensure their reporting systems and operational practices can adhere to the standardisation.

APRA consults directly on the public disclosure of information and will conduct further consultation in the future to consider the market sensitivity of any information before any public disclosures, e.g. in statistical publications.

Use of business day as an alternative to calendar days

One submission suggested that APRA should continue to specify due dates using business days, as ADIs may experience disruption due to public holidays. Given that public holidays are determined nationally and also by each state, APRA prefers to avoid the ongoing variation in due dates that using business days create. Furthermore, APRA considers that, since the standardised due date to 35 calendar days extends the due date for most forms, this is sufficient to alleviate any delays caused by public holidays. 

Response to consultation

APRA has considered submissions from the consultation and will implement the due date of 35 calendar days after the reporting period for all quarterly reporting forms, except for the modernised Economic and Financial Statistics (EFS) reporting forms.

For non-EFS reporting forms that were due before 35 calendar days, APRA will keep the existing extension. These forms will continue to be due on the 35th calendar day. APRA will formally update the due dates in the relevant reporting standards when they are next revised.

For forms that were due after calendar day 35, APRA will update the reporting due date to 35 calendar days when it revises the respective reporting standards and will notify affected ADIs during public consultation on these revisions. Until then, the due dates for these returns remain as specified in the reporting standard.

EFS data collection quarterly reporting

As communicated in the November 2020 letter to industry2, the Australian Bureau of Statistics has investigated the impacts of changing the quarterly EFS reporting due dates on the GDP publications. As a result, APRA and the ABS and have agreed to keep the due date of quarterly EFS forms at 28 calendar days after the end of the quarter to maintain the timely production of these publications.

Reporting Form ARF 210.4 3-year Funding Plan (ARF 210.4)

ARF 210.4 is also due on the 28th calendar day after the reporting period, but is due on an annual basis. To avoid confusion, APRA has also extended the due date for this return to the 35th calendar day, effective 1 April 2021.

A full list of affected reporting forms and their previous due dates is presented in the Appendix to this letter.

Yours sincerely,

 

Alison Bliss
General Manager
Data Analytics and Insights 

Footnotes

1 Changes to reporting obligations in response to COVID-19
2 Proposed changes to modernised Economic and Financial Statistics reporting standards and guidance 

Attachment – Schedule of revised quarterly ADI and RFC reporting due dates

The reporting forms specified in the below schedule will be due by 35 calendar days after the end of the quarter. 

For reporting forms that were due before 35 calendar days, this is effective immediately and formalises the extension granted 1 April 2020. 

For reporting forms that are currently due after 35 calendar days, the change will come into effect when APRA next revises the respective reporting standards. APRA will announce when this change will occur when it consults on revisions to these reporting standards.

Reporting form
Subject
Previous due date

ARF 110.0.1 Capital adequacy (Level 1)

ARF 110.0.2 Capital adequacy (Level 2)

ARF 111.0 Fair Values

Capital adequacy

30 business days (BD) – Advanced banks

20 BD – Standardised banks and other ADIs

15 BD – CUBS

ARF 112.1A Standardised credit risk – On-balance sheet assets

ARF 112.2A Standardised credit risk – Off-balance sheet exposures

Credit risk - standardised

20 BD

ARF 113.0A – ARF 113.0E Foundation Internal Ratings-based (FIRB) Approach to Credit Risk

ARF 113.1A – ARF 113.1E Advanced Internal Ratings-based (AIRB) Approach to Credit Risk

ARF 113.2 Internal Ratings-based (IRB) Approach to Credit Risk – Specialised Lending Supervisory Slotting

ARF 113.3A – ARF 113.3D Internal Ratings-based (IRB) Approach to Credit Risk - Retail

ARF 113.4 Internal Ratings-based (IRB) Approach to Credit Risk – Other Assets, Claims and Exposures

Credit risk - advanced

30 BD

ARF 114.0 Standardised Approach – Operational risk

Operational risk - standardised

30 BD – Advanced banks

20 BD – Standardised banks and other ADIs

15 BD – CUBS

ARF 115.0 Advanced Measurement Approaches (AMA) to Operational Risk

Operational risk - advanced

30 BD

ARF 116.0 – ARF 116.0.23 Market risk table

ARF 116.0.SU Market risk summary table

Market risk - standardised

30 BD – Advanced ADIs

20 BD – All other ADIs

ARF 117.0A Repricing analysis – denominated in AUD

ARF 117.0B.1 – ARF 117.0B.9 Repricing Analysis – denominated in foreign currency

15 BD – CUBS

20 BD – Branches of foreign banks, standardised banks, other ADIs

30 BD – Applicant/advanced banks

ARF 117.1 Interest rate risk in the banking book

Market risk - advanced

30 BD

ARF 118.0 Off-balance sheet business

Credit risk - standardised

15 BD – CUBS

20 BD – Branches of foreign banks, standardised banks, other ADIs

30 BD – Applicant/advanced banks

ARF 118.1 Other Off-Balance Sheet Exposures

Credit risk - advanced

28 calendar days (CD)

ARF 120.1 Securitisation – Regulatory Capital

ARF 120.2 Securitisation – Supplementary items

Securitisation

28 CD

ARF 180.1 Standardised – Counterparty Credit Risk and CVA Risk

ARF 180.2 IRB – Counterparty Credit Risk and CVA Risk

Credit risk – standardised and advanced

28 CD

ARF 210.1A Liquidity Coverage Ratio – all currencies

ARF 210.1B Liquidity Coverage Ratio – AUD only

ARF 210.2 – Minimum Liquidity Holdings Ratio

ARF 210.3.1 Contractual Maturity Mismatch – Funded Assets

ARF 210.3.2 Contractual Maturity Mismatch – Funding Liabilities and Capital

ARF 210.4 3-year Funding Plan

ARF 210.6 Net Stable Funding Ratio

Liquidity

28 CD

ARF 220.0.C Impaired Facilities (Consolidated)

ARF 220.0.L Impaired Facilities (Licensed)

ARF 220.3 Prescribed Provisioning

ARF 220.5 Movements in Provisions for Impairment

Credit risk

20 BD - Banks

15 BD – CUBS and other ADIs

ARF 221.0 Large Exposures

ARF 221.1 Large Exposures – Foreign ADI

Large exposures

28 CD

ARF 222.0 Exposures to Related Entities

Related entities

20 BD – Banks

15 BD – CUBS and other ADIs

ARF 223.0 Residential Mortgage Lending

Residential mortgage lending

28 CD

ARF 226.0 Margining and risk mitigation for non-centrally cleared derivatives

Credit risk

28 CD

ARF 230.0 Commercial Property

Commercial property

20 BD

ARF 322.0 Statement of Financial Position (Consolidated)

Financial statements

28 CD

ARF 323.0 Statement of Financial Position (Licensed)

Financial statements

28 CD

ARF 325.0 International Operations

Financial statements

20 BD

ARF 330.0.C Statement of Financial Performance (Consolidated Group)

ARF 330.0.L Statement of Financial Performance (Licensed ADI)

ARF 330.1.C Interest Income and Interest Expense (Consolidated Group)

ARF 330.1.L Interest Income and Interest Expense (Licensed ADI)

ARF 330.2.C Other Operating Income (Consolidated Group)

ARF 330.2.L Other Operating Income (Licensed Entity)

ARF 330.3 Other Operating Expenses

Financial statements

25 BD – Banks and other ADIs

15 BD - CUBS

ARF 731.1 International Banking Statistics – Locational Data

ARF 731.3A International Banking Statistics – Immediate and Ultimate Risk Exposures – Domestic Entity

ARF 731.3B International Banking Statistics – Immediate and Ultimate Risk Exposures – Foreign Entity

ARF 731.4 International Banking Statistics – Balance Sheet Items

 

International banking statistics

28 CD

ARF    760.0     ATO Collection for Major Bank Levy

 

Other requirements

 

30 BD

2021