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, Aktia and Finance Finland.
1. Opening remarks
- The BoF states that the main theme of the meeting is to present the results of the complementary cost-benefit assessment (cCBA)
2. Approval of the minutes of the previous meeting and their summary
- The minutes of the previous meeting are approved, subject to an amendment that, contrary to previous information, there will be no separate table for framework agreements
3. Results of the cCBA (WG IRDD meeting on 7 September 2023)
- In the course of IReF preparations, the idea of loan-by-loan data collection on natural persons’ loans has emerged
- Borrowers would be identified by a pseudonymisation algorithm that is not accessible to NCBs. Hence, the identity of the borrowers would remain secret, but loans belonging to the same person could still be identified
- Reporters have found that loan-by-loan data collection entails more pros than cons, which was a more positive response than expected
- An industry representative voices a concern about extra work caused by the validation rules of the loan-by-loan data collection, since it will be laborious to revise information on loans involving contradictory information in the base system
- The collection of additional attributes on real estate loans is found expensive from the reporters’ perspective
- The extension of the data collection regarding off-balance sheet items will not cover everything off the balance sheet, but will likely include, for example, unutilised credit lines. There is not going to be a separate table for framework agreements
- An industry representative comments that the more granular the data collection becomes, the more massive its production process will be, and this should also be reflected in the reporting schedule
- The BoF responds that the submission period is anticipated to be two days longer compared to the present RATI survey
- The cost of submission of attributes related to climate change are considered high in the industry. The BoF finds it unlikely that the requirements will pass into the IReF as such
- The starting point of the IReF reporting schedule is the proposal included in the previous CBA survey, which includes features from the schedules of the AnaCredit Regulation and Luoti data collection
- As regards the schedule, it is key that the requirements of the BSI and MIR Regulations are met, since the ECB will use these statistics for example in the preparation of monetary policy decisions
- Harmonisation of the conceptual framework with the FINREP solo level is considered absolutely useful, and it is likely to take place