Response to consultation on ITS amending Implementing Regulation (EU) No 680/2014 with regard to operational risk and sovereign exposures
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In relation to the costs of the new reporting template C17.02, members are less certain but estimate, without a large degree of confidence that it would result in similar costs.
Question 1: Could you please quantify both the implementation costs and recurring production costs (expressed in man days) that would arise when implementing the changed reporting requirements on OpRisk as part the regular reporting framework? How would these recurring production costs compare to a situation in which institutions were required to comply with ad-hoc data requests that are required to comply with current competent authorities’ requests on institutions’ OpRisk losses (e.g. SSM short-term exercise)? [see page 16]
Feedback received from some ESBG members suggests that the implementation costs of C17.01 would be 2 people/day, with recurring production costs of 0.5 people/day. These costs, members have opined, are similar to other requests like the SSM short-term exercise.In relation to the costs of the new reporting template C17.02, members are less certain but estimate, without a large degree of confidence that it would result in similar costs.