EBA has published its finalised guidelines on how confidential information collected under the Bank Recovery and Resolution Directive (BRRD) should be disclosed in summary or collective form without identifying individual institutions or relevant entities. The guidelines set out three principle-based factors to consider, relating to:
- the number of institutions to which the disclosure relates;
- the avoidance of specific patterns which could lead to the entity’s identification; and
- the avoidance of revealing elements of the context of the disclosure, such as addresses or timings, which could lead to the entities being identified.