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Krajowy Związek Banków Spółdzielczych

All public institutions which collect supervisory, prudential and statistical data. In case of Poland it should be Ministry of Finance, the National Bank of Poland, Polish Financial Supervision Authority and Bank Guarantee Fund.
The document does not explicitly specify which authorities both on national and European level should be included in the process of establishing the Integrated Reporting System. We are of the opinion that the scope of authorities involved in the Integrated Reporting System should be as broad as possible.
The article 430c of CRR refers to the concept of competent authorities which is defined in CRR in the article 4(1)(40) CRR as 'competent authority' means a public authority or body officially recognised by national law, which is empowered by national law to supervise institutions as part of the supervisory system in operation in the Member State concerned”. In case of Poland it would limit the institutions only to the Polish Financial Supervisory Authority, https://www.eba.europa.eu/supervisory-convergence/supervisory-disclosure/competent-authorities.
From the text of the presented document we infer that indeed all the national and European authorities involved in collection of supervisory, prudential and statistical data will be involved, following the broader definition of a “competent authority” as set in the article 4(1) in Regulation (EU) No 1093/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European Supervisory Authority (European Banking Authority).
The desirable objectives of an integrated reporting system should be to reduce the number and frequency of ad hoc requests. There is therefore a risk that banks will have to face both a more granular system and persisting ad hoc requests. We see a need for a clear commitment from authorities to reduce the number of ad hoc requests and invest more time in digging into the granular data that they would receive. For this reason the feasibility study should consider as the broadest range of data as possible, comprising supervisory, prudential and statistical data, collected based on both European and national requirements. Any further future requirements imposed on banks by the authorities using the integrated reporting system should be always included in the integrated reporting framework.
The options are in our opinion not complete. The paper focused mostly on the data collection in the euro area countries (19 out of 27 in the European Union). In case of Poland (non-euro country) the data collection is organized slightly differently than presented in the paper. Firstly, most of the data are collected by the National Bank of Poland which are then shared with other institutions. Secondly, the regulations of the European Central Bank such as AnaCredit or future Integrated Reporting Framework (IReF) do not apply in Poland and therefore it would be a challenge to create a data model which would satisfy the data needs and at the same time not imposing new obligations on banks which would lead to indirect introduction of ECB’s regulations.
Lastly, in case of data collected from the most of cooperative banks, the data are in the first place transmitted in proper forms to the banks associating cooperative banks ( there are two cooperative groups in Poland) and these two banks transfer the data to the relevant institutions. This kind of arrangement would be also challenging for implementation of the integrated reporting framework.
We would also very much appreciate if the rough estimate of costs of implementation of the integrated framework was provided.
Not relevantSomewhat relevantRelevantHighly relevant
Training / additional staff (skills)   X
IT changes  X 
Changes in processes  X 
Changes needed in the context of other counterparties / third-party providers  X 
Time required to find new solutions  X 
Other (please specify)  X 
We see the current set up of the process of coordination of inventory of data needs and data definitions at the level of public institutions at national level as one of the key obstacles and operational challenges. Currently there are many national additions in the data collections and it would be challenging to streamline them and square them into a single data model.
The key challenge in the process of building an integrated reporting system is to maintain the principle of proportionality. Proportionality in reporting is currently embedded via the templates. Such an approach would be hard to implement in a framework with increased granularity and fundamentally data driven. We believe that proportionality should get a prominent place in discussions regarding integrated reporting system.
No additional information
Highly agreeAgreeSomewhat agreeDon’t agree
Data Dictionary - Semantic levelX   
Data Dictionary - Syntactic level X  
Data Dictionary - Infrastructure level  X 
Data collection - Semantic levelX   
Data collection - Syntactic level X  
Data collection - Infrastructure level  X 
Data transformation - Semantic levelX   
Data transformation - Syntactic levelX   
Data transformation - Infrastructure level  X 
Data exploration - Semantic level  X 
Data exploration - Syntactic level  X 
Data exploration - Infrastructure level  X 
No additional comments
For smaller banks more granular reporting means building infrastructure for data never collected before. This could mean considerable initial investments but also higher ongoing costs. We believe that the principle of proportionality must be taken into account here.
One of the key issue will be also the proper data governance including who and when accesses the data. We believe that banks should be involved in the governance of the reporting system.
Yes, we use many reporting dictionaries, depending on the reporting framework. Each reporting framework is a separate model and their concepts do not match.
The dictionary should cover all requirements, both European as well as national, including ad-hoc requests. The concepts should be matched to the existing definitions in legislation other than designed for statistical data collection.
The dictionary should be a complete inventory of concepts that the regulators can use while imposing new international or national obligations. The data requests should be limited to the concepts present in the dictionary. Any new concept introduced into the dictionary should be put in relation to the existing ones, e.g. if a new concept is a sub-domain of any existing concept.
SignificantlyModeratelyLow
Understanding reporting regulationX  
Extracting data from internal system  X
Processing data (including data reconciliation before reporting)  X
Exchanging data and monitoring regulators’ feedbackX  
Exploring regulatory dataX  
Preparing regulatory disclosure compliance. X 
Other processes of institutions X 
All the regulations would refer to the same concepts and it would be easier to point to the data in the internal systems.
The concepts in the dictionaries still need to be linked to the internal systems.
Already now there are algorithms that know which data to take from our databases. An introduction of a new data dictionary would mean that the work to map data needs to be re-done for the existing reporting frameworks.
If the dictionary is merely a catalogue of concepts without specifying any relations between them, the data processing would not be simplified.
A data dictionary would give a chance of creating a knowledge database where the regulator’s feedback refers to a specific datapoint.
A clear and unified definitions across regulations would help in exploring regulatory data.
Important
Highly costly
High cost reductions
High cost reductions
The scope of reporting obligations of data exceeds the statistical, supervisory and resolution reporting. A clear catalogue of concepts used by regulators both on international and national level as well as the relations between the concepts would be of much help for ensuring the data quality and integrity.
No additional comments
  • statistical
  • resolution
  • prudential
option 1
The rank of options regarding the granularity of the possible future integrated reporting system:
option 1 - the most feasible and the most preferable,
option 2 - less feasible and less preferable,
opion 3 - the least feasible and the least preferable.
No additional comments
Double checking the correctness of calculations performed by the institutions
Double checking the correctness of calculations performed by the institutions
No additional comments
The option 2 should avoid double reporting by banks and at the same time the responsibility of the correctness of data aggregation should be in the public authority, not the reporting bank.
Highly (1)Medium (2)Low (3)No costs (4)
Collection/compilation of the granular dataX   
Additional aggregate calculations due to feedback loops and anchor values X  
Costs of setting up a common set of transformations* X  
Costs of executing the common set of transformations** X  
Costs of maintaining a common set of transformations X  
IT resourcesX   
Human resourcesX   
Complexity of the regulatory reporting requirementsX   
Data duplicationX   
Other: please specifyX   
Highly (1)Medium (2)Low (3)No benefits (4)
Reducing the number of resubmissions  X 
Less additional national reporting requests X  
Further cross-country harmonisation and standardisation X  
Level playing field in the application of the requirements X  
Simplification of the internal reporting process X  
Reduce data duplications  X 
Complexity of the reporting requirements  X 
Other: please specifyX   
No additional comments
The authorities
Harmonised and standardised, ready to be implemented by digital processes (fixed)
Regardless of the scenario applied, the reporting institutions should remain responsible only for the data they submit, not the data calculated by the authorities. Taking the responsibility by reporting banks for the data aggregated by the authorities would anyway mean implementation of the defined transformations in banks in order to ensure the data and possibly detect some inconsistencies in advance
Manual adjustments should be allowed, however the transformation process should be streamlined. The reporting institutions should be given a possibility to suggest changes to the calculation process.
No additional comments
No additional comments
No additional comments
No additional comments
No additional comments
The feedback loop data depends on the granularity of the data collection to applied. The feedback loops should always give some additional information to the institutions which they had not have before, as for example it is currently the case of AnaCredit.
The key cost driver for the implementation of the new reporting system is the timeline. When the new dictionary is set up, it must be flexible enough to be implemented by all banks and authorities, easy to update and adjust.
Data driven environment (particularly at supervisory level) should be considered also at the level of originating legislative proposals and designing of the relevant regulatory requirements. While this dimension is missing in the consultation, it is essential to take this into account at an early stage to avoid having to introduce incremental fixes that only weigh on the overall complexity of reporting and related costs
Yes
Not applicable
The obligation for banks to provide the same or almost the same information with different frequency in different reports
Obligation for banks to complete ad-hoc questionnaires containing data provided in other reports
The new reporting obligations for the resolution purposes which duplicate a significant part of the information contained in other reports
Different concepts used by different institutions
Duplication of data points (also in case of reports submitted to the same institution)
Multiple dictionaries
Each reporting framework has a defined transformation process with concepts mapped to the bank’s database
Different formats
No additional comments
Somehow important
We are aware of the data which were submitted
All public institutions which collect data from banks should collect data only through the CDCP. No other data collection, even ad-hoc, should be allowed.
No additional comments
No additional comments
No
not valuable at allvaluable to a degreevaluablehighly valuable
Data definition – Involvement   X
Data definition – Cost contribution   X
Date collection – Involvement   X
Date collection – Cost contribution   X
Data transformation – Involvement   X
Data transformation – Cost contribution   X
Data exploration – Involvement  X 
Data exploration – Cost contribution  X 
Data dictionary – Involvement X  
Data dictionary – Cost contribution X  
Granularity – InvolvementX   
Granularity – Cost contributionX   
Architectures – Involvement X  
Architectures – Cost contribution X  
Governance – Involvement  X 
Governance – Cost contribution  X 
Other – InvolvementX   
Other – Cost contributionX   
No additional comments
No additional comments
No additional information
A push approach
A pull model needs to address questions of realtime availability in the bank of oversight on data. "Data room" solutions might be needed, or the use of possible cutoff dates for institutions to generate the data. Solutions could also envisage “data days” when supervisors will/may pull the data. It should also be noted that supervisors might perform all kinds of aggregations and deep dives with the data pulled, institutions would need to be able to know what kind of queries were pulled e.g. to replicate what supervisors did.
Costs - infrastructure which is always ready for the pull from the authorities’ side
Challenges - the data may not be ready in the model required at the time when the authority would pull the data
Benefits - the bank prepares data and sends them when they are ready
Challenges - putting data into a desired model
No additional comments
No additional comments
Not all of the institutions should have access to the same set of data
The calculations would need to be redone in order to double-check the data correctness. There would be not less but more work in case of performing calculations by authorities
No additional comments
No additional comments
In the first place, the coordination committees should be organized at national levels. Already now the public institutions collecting statistical, supervisory and resolution data have duplicated data needs.
Alternatively, the reporting hub should be organized by one of the data collectors. In the case of Poland, it could be the central bank
No additional comments
No additional comments
As mentioned earlier:
reduce the number and frequency of ad hoc requests,
proportionality,
for smalle banks more granular reporting means building infrastructure for data never collected before - in that field more verification is necessary,
the proper timeline for implementation,
banks should be involved in the governance of the reporting system.
  • Data collection
  • Data transformation
Not fully developed or useful for my needs
Data definition
It is hard to imagine how a common data model which would include the concept of ECB’s IReF would be implemented in non-euro area countries. Also, from the paper, it was not clear which data collections would be integrated.
Secondly, the issue of multi-level data collection in case of cooperative banks – the data collection in such a case is more complex than described in the paper and there are many institutions which would be affected if a European regulation is in place.
in-house
The volume and complexity of financial regulations have increased significantly since the 2008 financial crisis. This has put increasing pressure on banks to monitor and report a range of intricate exposures to comply with new prudential requirements. The automation of processes can allow for better and more efficient risk identification and regulatory compliance.
Yes
Jacek Rapcia
K