EN
OPINION OF THE EUROPEAN CENTRAL BANK
of 26 January 2004
at the request of Sveriges Riksbank on draft regulations and general advice on the reporting by
institutions of money and banking statistics 
(CON/2004/2)
1. On 8 December 2003, the European Central Bank received a request from Sveriges Riksbank for an
opinion on a draft proposal to amend and replace its regulations and general advice on the reportingby monetary financial institutions of money and banking statistics ( Riksbankens föreskrifter och
allmänna råd  (RFBS 2003:2) om instituts rapportering av finansmarknadsstatestik ) (the “draft
regulations”). 
2. The ECB’s competence to deliver an opinion is based on the second indent of Article 105(4) of the
Treaty, the second indent of Article 4(a) of the Statute of the European System of Central Banksand of the European Central Bank and the fourth  indent of Article 2(1) of Council Decision
98/415/EC of 29 June 1998 on the consultation of the European Central Bank by nationalauthorities regarding draft legislative provisions
1 as the draft regulations relate to the collection,
compilation and distribution of monetary, financial and banking statistics. In accordance with thefirst sentence of Article 17.5 of the Rules of Procedure of the European Central Bank, theGoverning Council of the ECB has adopted this opinion.
3. The main body of the draft regulations consists of a set of rules ( föreskrifter ), with each rule being
accompanied by general advice ( allmänna råd ) providing explanations on implementation of the
corresponding rule (Articles 1 to 10 of the draft regulations). These rules and general advice referto the scope and definitions used for the collection of statistics, the institutions covered by thereporting obligations and the frequency and timeliness for reporting data. They also specify theform and content of the statistical reporting, how  to present amounts, the treatment of assets and
liabilities and data archiving. 
4. In addition, 11 annexes contain the forms used by monetary financial institutions (MFIs) to report
data from their balance sheets (referred to as ‘MFI forms’) and technical specifications for thevarious balance sheet and other items subject to reporting obligations. The technical specifications
                                                
1 OJ L 189, 3.7.1998, p. 42.
2for the items to be reported refer frequently to the Swedish Financial Supervisory Authority’s
regulations and general advice on annual accounts for credit institutions and securities dealers(Finansinspektionens föreskrifter och allmänna råd (FFFS 2003:11) om årsredovisning i
kreditinstitut och värdepappersbolag ) (the “FSA regulations”), particularly to definitions of terms
used for reporting purposes. The Riksbank’s draft regulations entered into force on 1 January 2004and the ECB understands that the FSA regulations ha ve been scheduled to enter into force on the
same date. The ECB did not, however, receive the final version of the new FSA regulations as a
part of the current consultation and does not express a definite view on how they will affectSveriges Riksbank’s new regime for collecting statistics.
5. The ECB welcomes the proposed draft regulations as they implement a large part of the money and
banking statistical requirements for the balance shee t of the MFIs in the euro area and are broadly
consistent with the ECB's statistical requirements for minimum reserves. While Sweden has noobligation to implement these requirements before adopting the euro, the ECB stronglyrecommends convergence with ECB statistical reporting schemes for Member States with aderogation to enable timely preparations in the field of statistics in order to become participatingMember States. This opinion focuses on the statistical requirements in Regulation ECB/2001/13 of22 November 2001 concerning the consolidated balance sheet of the monetary financial institutionsector
2, as last amended by Regulation ECB/2003/10.
6. The draft regulations now proposed by the Riksba nk are addressed to banks and a number of other
financial institutions. The ECB understands that the Riksbank plans to include, later this year,money market funds (MMFs) in the list of reporting institutions. The ECB welcomes this as itwould be in line with Regulation ECB/2001/13 and would seem appropriate considering the
references to MMFs already contained elsewhere in the draft regulations (for instance, in the main
special balance sheet table). Furthermore, the E CB refers to ECB Opinion CON/2003/10 of 20 June
2003 at the request of the Swedish Ministry of Finance on a proposed legislative reform of Swedishbanking and financial law. This legislative reform proposed abolishing the banks’ monopoly ondeposit taking. The ECB recommends extending the money and banking data collection to thoseinstitutions that are non-banks and taking deposits from the public, in line with the definition ofMFIs contained in Article 1(1) of Regula tion ECB/2001/13, and without prejudice to the
application of Article 1(2) thereof.
7. The ECB notes that the Riksbank’s draft regulations address two central elements: (a) the forms
used by MFIs to report data from their balance sheets, in view of new ECB requirements in thecurrent version of Regulation ECB/2001/13; and (b) certain requests concerning financial accountsfrom Statistics Sweden ( Statistiska centralbyrån,  SCB)
3. The draft regulations cover most of the
                                                
2 OJ L 333, 17.12.2001, p. 1.
3 With regard to the role of Statistics Sweden in relation to the Riksbank’s production of statistics, see also ECB Opinion
CON/2002/21 of 14 August 2002 at the request of Sveriges Riksbank on a draft legislative proposal to amend the
3requirements in Regulation ECB/2001/13. Neverthele ss, the following breakdowns of stocks are
not included. 
7.1. The monthly breakdown by purpose of the loans granted to households, as required in
Table 1 of Regulation ECB/2001/13.
7.2. Table S2 of the draft regulations specify item No 203 on debt securities issued, a residency
breakdown of the holders of securities up to one year, but not of those over one and up totwo years, as required in Article 2(5) of Guideline ECB/2003/2 of 6 February 2003
concerning certain statistical reporting requirements of the European Central Bank and theprocedures for reporting by the national central banks of statistical information in the field ofmoney and banking statistics
4.
7.3. The ECB’s minimum reserve requirements provide for a separate identification of the
positions vis-à-vis institutions subject to minimum reserve requirements. Before theRiksbank becomes a part of the Eurosystem, additional breakdowns would be needed toidentify these positions for both residents and non-residents in other Member States. 
8. The ECB proposes including the above breakdowns on the MFI forms, if not already covered by
other national reporting requirements, which is assumed to be the case at least in respect ofparagraph 7.1 above. The ECB also recommends so lving the following terminological problems.
8.1. In general, the expression ‘euro and EMU currencies’ should be replaced by ‘euro’ as the
latter would be clearer and the expression ‘EMU  currencies’ would not be appropriate after
the introduction of the euro (except maybe for banknotes and coins in nationaldenominations during a transitory period that ended in 2002); it could be indicated that‘euro’ comprises national banknotes of Member States that adopt the euro in the future incase a transitory period for the cash changeover is decided for such Member States. 
8.2. In Table S1 Accounts, maturity 1(10), specifying item No 201 deposits and borrowing-
counterparties by type of account and maturity, the deposits redeemable at notice are brokendown by ‘maturity’. The correct expression is ‘period of notice’.
8.3. The ESA95 sector S.125 is described in the draft regulations (in, for instance, Table T3
Overnight Loans 1(2) item No 1031133) as ‘ins urance corporations and pension funds’ for
residents in Sweden and ‘insurance corporatio ns’ for non-residents. It would be advisable to
use the same term or to explain the difference, as appropriate.
8.4. In the table specifying other EU currencies and other foreign currencies, these currencies
should not include positions denominated in euro. The table does not make this explicit.
                                                                                                                                                                          
Sveriges Riksbank Act (1988:1385) with regard to the co llection of balance-of-payments statistics and the liquidity
criterion for securities used in  monetary policy operations.
4 OJ L 241, 26.9.2003, p. 1.
49. A further important aspect of the draft regulations concerns the addition of a new section for
reporting revaluation adjustment in respect of flow s. The draft regulations are fully in line with the
requirements for the revaluation adjustment in Regulation ECB/2001/13. Furthermore they extendthe data reporting beyond the “minimum” requirement, to cover all breakdowns included inTable 1A of Regulation ECB/2001/13. The ECB welcomes this. 
10. The draft regulations also entail introducing new references in the country and currency
specifications to the countries expected to become new EU Member States from May 2004 (the“acceding countries”). Subject to the above recommendations, the ECB also welcomes theseamendments.
11. Moreover, the draft regulations contain an additional breakdown of lending by maturity and a more
coherent breakdown by sector that is also in line with Regulation ECB/2001/13. At present,
however, a breakdown of the loans granted to households by purpose has not been included. Thisinformation is considered relevant to the monetary analysis of credit to residents.
12. The ECB understands that the draft regulations are not intended to collect data on interest rates
applied by MFIs to deposits and loans vis-à-vis households and non-financial corporations (MIR)as contained in Regulation ECB/2001/18 of 20 December 2001 concerning statistics on interestrates applied by monetary financial institutions to deposits and loans vis-à-vis households and non-financial corporations
5. Nevertheless, given that the draft regulations contain some requirements
for the amounts of new business on loans, the ECB notes that the draft regulations do not fullycover the requirements for MIR statistics.
13. The ECB confirms that it has no objection to the competent national authorities making this
opinion publicly available at their discretion. This  opinion will be published on the ECB’s website
six months after the date of its adoption.
Done at Frankfurt am Main on 26 January 2004.
[signed]
The President of the ECB
Jean-Claude TRICHET
                                                
5 OJ L 10, 12.1.2002, p. 24.