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)
Date: 2004-01-26
Institutions: European Central Bank
Subjects: data collection, financial institution, financial statistics, statistics

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 reporting

by  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 Banks

and  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  national
authorities  regarding  draft  legislative  provisions1  as  the  draft  regulations  relate  to  the  collection,

compilation and distribution of monetary, financial and banking statistics. In accordance with the

first  sentence  of  Article 17.5  of  the  Rules  of  Procedure  of  the  European  Central  Bank,  the

Governing 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 refer

to  the  scope  and  definitions  used  for  the  collection  of  statistics,  the  institutions  covered  by  the

reporting  obligations  and  the  frequency  and  timeliness  for  reporting  data.  They  also  specify  the

form 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  the

various balance sheet and other items subject to reporting obligations. The technical specifications

1 

OJ L 189, 3.7.1998, p. 42.

                                                
for  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 2004

and the ECB understands that the FSA regulations have 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  affect

Sveriges 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 sheet of the MFIs in the euro area and are broadly

consistent  with  the  ECB's  statistical  requirements  for  minimum  reserves.  While  Sweden  has  no

obligation  to  implement  these  requirements  before  adopting  the  euro,  the  ECB  strongly

recommends  convergence  with  ECB  statistical  reporting  schemes  for  Member  States  with  a

derogation to enable timely preparations in the field of statistics in order to become participating

Member States. This opinion focuses on the statistical requirements in Regulation ECB/2001/13 of

22 November 2001 concerning the consolidated balance sheet of the monetary financial institution
sector2, as last amended by Regulation ECB/2003/10.

6. 

The draft regulations now proposed by the Riksbank 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  it

would  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 ECB 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 Swedish

banking  and  financial  law.  This  legislative  reform  proposed  abolishing  the  banks’  monopoly  on

deposit taking. The ECB recommends  extending  the  money  and  banking  data collection to  those

institutions  that  are non-banks  and  taking  deposits  from  the  public,  in  line  with  the  definition  of

MFIs  contained  in  Article  1(1)  of  Regulation  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  the

current version of Regulation ECB/2001/13; and (b) certain requests concerning financial accounts
from  Statistics  Sweden  (Statistiska  centralbyrån,  SCB)3.  The  draft  regulations  cover  most  of  the

2 
3 

OJ L 333, 17.12.2001, p. 1.
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

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requirements  in  Regulation  ECB/2001/13.  Nevertheless,  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 to

two  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 the

procedures for reporting by the national central banks of statistical information in the field of
money and banking statistics4.

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  the

Riksbank  becomes  a  part  of  the  Eurosystem,  additional  breakdowns  would  be  needed  to

identify 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  of

paragraph 7.1 above. The ECB also recommends solving 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  national

denominations  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  in

case 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 broken

down 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 ‘insurance corporations and pension funds’ for

residents in Sweden and ‘insurance corporations’ 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  collection  of  balance-of-payments  statistics  and  the  liquidity
criterion for securities used in monetary policy operations.
OJ L 241, 26.9.2003, p. 1.

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9. 

A  further  important  aspect  of  the  draft  regulations  concerns  the  addition  of  a  new  section  for

reporting revaluation adjustment in respect of flows. The draft regulations are fully in line with the

requirements for the revaluation adjustment in Regulation ECB/2001/13. Furthermore they extend

the  data  reporting  beyond  the  “minimum”  requirement,  to  cover  all  breakdowns  included  in

Table 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  these

amendments.

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. This

information 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  interest

rates applied by monetary financial institutions to deposits and loans vis-à-vis households and non-

financial  corporations5.  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  fully

cover 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.

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