Place: Bank of Finland / Microsoft Teams
Present: Officials of the Bank of Finland (BoF). Industry representatives from the Savings Banks Group, OP Financial Group, ALM Partners and Aktia.
1. Update from the ECB
- Central banks within the European System of Central Banks have to assess the costs and benefits of IReF requirements in euro terms in the ECBA cost survey
- This is a so-called interim survey, which will be repeated in about a year.
- The industry may also choose to participate in the survey through the EBF, which also responds to the survey.
- The EBA (European Banking Authority) and the ECB have established a Joint Bank Reporting Committee (JBRC).
2. Analysis of responses to the cCBA
- Split of outstanding nominal amount
- According to industry participants present in the small working group, splitting is not a problem, since the components of outstanding nominal amount are available separately in the systems
- This issue will certainly be discussed in more depth in the course of the IReF preparations
- Tracking of internal instrument identifiers
- Changes to internal instrument identifiers are currently prohibited in the AnaCredit data collection.
- There is support for removing this requirement in the IReF and incorporating the tracking of these changes into the IReF systems.
- Attributes related to climate change
- There is consensus about the importance of the matter and the need for tracking
- However, the costs are generally high
- Nevertheless, there is support for collecting the address and 4-digit industry code
- Collection of protection allocated values under the CRR
- Collection of this data on a quarterly basis could reduce costs
- Collection of governing law of loan agreements
- It looks like this attribute will not be collected.
- Collection of protection issuer and value
- Collection of the issuer is still examined
- Collection of non-IRB PD values
- Other PD values than those generated by an IRB model could also be collected if the type of PD value is reported separately.
- Manner of data submission
- Resubmission of the whole report in the event of revision is considered the best practice.
- Reporting schedule
- A schedule with two monthly submissions and one quarterly submission is considered the most sensible.
- Early submission of counterparty reference data
- According to the proposal, this data should be reported concurrently with the reportable balance sheet data.