Response to consultation on revised Guidelines on stress tests of deposit guarantee schemes

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Question 4: Do you have any comments on the proposals to address the issues related to the design, execution and reporting of SCV files stress tests, in particular the differentiation into two categories of SCV files stress tests (as proposed in Guideline 4.7), stress testing the SCV files of all relevant institutions (Guideline 4.9), and the definition of substandard entries (Guideline 4.19)?

Please consider data quality through technology as well. If all member institutions use the same IT-system, data quality checks through technology are efficient for validating data.

In practice it is possible that the banks customer database is predefined by the system and includes mandatory fields that have to be filled in by the employees of the bank in the correct format. This ensures that the DGS would have all the necessary information for carrying out a refund in the event of a failure of a bank, and thus all SCV files would be (automatically) valid.
The mandatory fields contain additional “technical prechecks” and are mandatory to be filled in, in the given format during the initial creation. For example, the date of birth has to be entered and can only be an 8-digit number; the postal code has to be entered and can only be selected from a valid drop-down field.

Name of the organization

Sparkassen-Haftungs GmbH