La risk disclosure delle banche italiane: alcune considerazioni alla luce della regolamentazione vigente

(RISK DISCLOSURE OF ITALIAN BANKS: SOME CRITICAL THOUGHTS IN LIGHT OF THE CURRENT REGULATION). The issues of risk disclosure have been addressed, within the national and the international arena, by both academics and practitioners. Recent literature has shown that risk disclosure is not useful for stakeholders as it is not really detailed, not forward-looking, not sufficient for the assessment of the overall risk profile, and not relevant for the decision making process. Also, standard setters have often shed light on the lack of usefulness of risk disclosure. Over the last ten years, at the European level, several rules relating to risk disclosure have been issued from different regulators, thus defining a continuous raising of the minimum requirements. To increase the usefulness of the external information, risk disclosure regulation defines not only quantitative parameters but also qualitative aspects to be complied with. However, the recent financial crisis has shown the failures of the regulatory system per se for several reasons. First of all, despite the constant effort of the European Union to ensure the comparability of risk disclosure, differences between specific home-country practices still persist. In addition, current regulation provides a certain degree of discretion to firms, which allows corporate insiders to convey private information that resides within the firm and to adapt reports so that they better reflect the underlying economic reality. In this regard, recent studies have highlighted the weakness of risk disclosure in terms of faithfulness, as it does not adequately reveal the effective risk exposure of firms. This research examines the different risk disclosure requirements, to be provided in three different documents (Nota Integrativa, Relazione sulla Gestione, Informativa al Pubblico – Terzo Pilastro) by focusing on qualitative information, which should provide more detailed insights relating to the choices of the management of risks. The aim of the paper is to find out the discretion allowed by the current regulation, by analysing both the enforcement level and the strengthen of the information required, in the attempt to discuss some possible effects in terms of comparability and faithfulness of risk disclosure. The analysis refers to the banking sector, which is a particular interesting field because of its distinguishing features. On one hand, banking activity mainly relies on management, measurement, control and communication of risks, which are the key-drivers of banking value creation. On the other hand, banks should comply with additional and specific regulatory requirements related to different sources of law, due to the fundamental role played in the economic system. In such a field, risk disclosure moves from a mere technical practice to a broader and relevant matter from the economical, political and social perspective, becoming crucial for different categories of stakeholders. More in depth, we focus on the Italian country setting, which has been identified, within a cross-country analysis, as an example of best practice for risk disclosure, mainly for the active and interventionist role played by the Supervisory Authority (Banca d’Italia), who issued additional administrative provisions for banks to apply the IFRS and the Basel II Accord, with the aim to increase the comparability of risk disclosure provided by the Italian banks. However, the different sources of law show some overlaps and/or lacks in their prescriptions so that they are not able to ensure the faithfulness of risk disclosure. This research aims at being relevant from a theoretical perspective, by contributing to risk disclosure literature through a critical analysis of the current risk disclosure regulation. It also provides a contribution for national and international standard setters, policy makers, and supervisory authorities, by highlighting some limitations of the complex system of risk disclosure regulation.