As a first step, we believe that the scope of the Feasibility Study should be limited to credit institutions that are required to report to CRR and national frameworks.
For small reporting credit institutions, a principle of proportionality should apply.
Data collections that should be considered are mainly those listed in the stocktake by the Feasibility Study, i.e. supervisory, resolution and statistics requirements at EU and national levels. Could also be included in the scope of the data collections other requirements such as SRB valuation data set (for the common part aligned with Anacredit) and Loan Tape standard (for the common part with Anacredit).
In addition, the scope of the data collections should be limited to the data required by the regulation without extending it to management data and without anticipating future regulations.
Furthermore, we would also like to stress that if reporting institutions could “report once”, harmonised and standardised data, i.e., produce a single report from which the relevant authorities could extract the data they require, it would be of great benefit to reporting institutions and authorities alike.
The EBA Discussion Paper on a Feasibility Study of an Integrated Reporting System under Article 430c CRR presents options for key areas in the development of an integrated reporting system across prudential, resolution, and statistical reporting in EU. It remains at a macro level of analysis and is neutral as to the technical results of an integrated reporting framework.
We believe that the two areas among the four core areas considered for the creation of an integrated reporting that are key for the success of the project are a unique and common data dictionary and the related governance aspects. They should be considered first, before moving on to the other topics, i.e. the Central Data Collection Point and the level of granularity of data, that, while relevant, can be discussed at a later stage.
Besides, the EBA feasibility study is launched shortly after the ECB published the Cost-Benefit Assessment (CBA) questionnaire on the same matter related to an integrated reporting system. We would have hoped closer interconnection between the ECB's Integrated Reporting Framework (IReF) and the EBA's feasibility study. We question the differences in terms of scope - the ECB project is limited to statistical data whereas the EBA project addresses a broader scope covering prudential, statistical and resolution reporting – and in terms of progress of the two projects – the implementation horizon of the ECB’s IReF is 2024 – 2027, whereas the EBA study remains at a macro level analysis. The alignment of the implementation of both projects is essential. Different implementation timetables and scopes would imply that reporting institutions will incur costs without the full benefit of an integrated reporting. They would have to overhaul their IT infrastructure after the implementation of ECB’s IReF, once the integrated reporting system for supervision, statistics and resolution is defined by the EBA.
Training / additional staff (skills)
Changes in processes
Changes needed in the context of other counterparties / third-party providers
Time required to find new solutions
Other (please specify)
We share the preliminary conclusions related to the stocktake of the current reporting framework to be included in an integrated reporting system, i.e., prudential, statistical, resolution data.
In addition, could be considered other requirements such as SRB valuation data set (for the common part aligned with Anacredit) and Loan Tape standard (for the common part with Anacredit).
Besides, one of the desirable objectives of an integrated reporting system is to reduce the number and frequency of ad hoc requests. While national data may be needed to fulfil national needs or ad hoc data may arise as the result of specific situations, we encourage authorities to have a clear commitment to issue fewer ad hoc requests and to reuse granular data already reported, so to provide a relief for the reporting institutions regarding their reporting burden.
Data Dictionary - Semantic level
Data Dictionary - Syntactic level
Data Dictionary - Infrastructure level
Data collection - Semantic level
Data collection - Syntactic level
Data collection - Infrastructure level
Data transformation - Semantic level
Data transformation - Syntactic level
Data transformation - Infrastructure level
Data exploration - Semantic level
Data exploration - Syntactic level
Data exploration - Infrastructure level
Banks use multiple dictionaries, usually a combination of external reporting dictionaries from authorities and internal dictionaries.
Besides, it should be noted that banks consider the DPM as a reference to fill in templates and perform controls. The DPM could not be considered and used as a dictionary as it is a technical tool and does not contain any definition. It could only be appended to the data dictionary.
Building up a common glossary should start from the existing regulatory frameworks and the assessment of the degree of common definitions and concepts that already exist. The common dictionary should also be elaborated in connection with the initiative of the Integrated Reporting Framework of the ECB. As considered in the study, the priority must be given to the principle commonly referred to “define once”, i.e., a common language and dictionary with consistent definitions applicable to a large scope of data requested including statistical, prudential and resolution data as it is not in the interest of either the reporting institutions or the authorities to pile up data dictionaries developed by different authorities.
Accordingly, while we agree that the alignment of the semantic level (data definitions), the syntactic level (Metadata Model and Logical Data Model) and the infrastructure level (Database) is important, we believe that the starting point of the data dictionary is the alignment of the concepts and definitions used in of all the regulatory frameworks, i.e. prudential, resolution and statistics reporting and by all authorities at UE and national levels.
Besides, when a new data dictionary is to be implemented, it should be flexible enough to be implemented by all banks, easy to update, taking into consideration the costs of IT systems and internal processing updates when it comes to deciding on the frequency of data developments.
Furthermore, if reporting institutions could “report once”, harmonised and standardised data, i.e., produce a single report from which the relevant authorities could extract the data they require, it would be of great benefit to reporting institutions and authorities alike.
A unique data dictionary should be the “one language” used and shared by authorities and credit institutions. At the level of credit institutions, it will contribute to produce all regulatory requests in less burdensome and more efficient manner. By using uniform definitions, it will improve data quality, contribute to a better and common understanding of the reporting requirements and avoiding multiple interpretations of the same item. At the level of authorities, it will improve comparability.
Understanding reporting regulation
Extracting data from internal system
Processing data (including data reconciliation before reporting)
Exchanging data and monitoring regulators’ feedback
Exploring regulatory data
Preparing regulatory disclosure compliance.
Other processes of institutions
Data dictionary should be used as a unique reference of common definitions and concepts for all regulatory frameworks
Processing data will facilitate reconciliation and controls, reducing data transformation
It is of utmost importance to have a unique and standard data dictionary for all regulatory purpose under every approach (template driven or granular driven) and at EU or national level.
There is a strong need of consistent and homogeneous definitions that are clearly understandable to ensure the coherence of the reporting framework and to contribute to reduce the reporting requirement overlaps.
It would be highly costly to implement a unique regulatory data dictionary, but the benefits would outweigh the costs as it will provide homogeneous definitions of items used in all reporting.
High cost reductions
Integrating national regulatory reporting would potentially highly reduce costs to the extent that such those reporting will rely on common notions and definitions even if the data are used for national purposes.
High cost reductions
A unique data dictionary will contribute to reduce costs provided that ad hoc requests will rely on definitions and concepts of the unique data dictionary and that they will be limited to specific purposes or specific situations and based on the reuse of data already reported regularly.
We consider that for all the reporting purposes the path for more granular data must be explored. But the decision of which templates or requests can be replaced by granular datasets must be conducted very carefully to assess their relevance and avoid any unintended consequences. Indeed, for the prudential reporting, legal constraints must be carefully assessed notably calculation of ratios: more relevant at consolidation level on an aggregated basis.
Option 2 would be the preferred option.
However, not all balance sheet items are relevant to be reported or can be explained at a granular level. Reporting on a granular basis is more appropriate for risk items, such as credit risk items. Other balance sheet items should remain at aggregated level within rules defined in accordance with the authorities.
No costs (4)
Collection/compilation of the granular data
Additional aggregate calculations due to feedback loops and anchor values
Costs of setting up a common set of transformations*
Costs of executing the common set of transformations**
Costs of maintaining a common set of transformations
Complexity of the regulatory reporting requirements
Other: please specify
No benefits (4)
Reducing the number of resubmissions
Less additional national reporting requests
Further cross-country harmonisation and standardisation
Level playing field in the application of the requirements
Simplification of the internal reporting process
Reduce data duplications
Complexity of the reporting requirements
Other: please specify
The elements that would contribute to the success of the implementation of the option 2 would not notably be an appropriate and well-defined transition to the data driven approach from the current template approach
Authorities and reporting institutions jointly
The responsibility of defining the transformation rules must be exercised jointly by the authorities and the reporting institutions. Thus, it is important that reporting institutions participate to the definitions of the transformation rules alongside with the authorities under a Joint Committee. Indeed, reporting institutions need to be able to know what type of queries or aggregations have been extracted, to replicate what supervisors have done and to be in capacity to answer to supervisors to any questions raised.
The responsibility of the correctness of the data reported remains to the credit institutions as the data are derived from their systems.
The execution of the transformation rules should be under the responsibility of the authorities, as reporting institutions could not be responsible of transformation of data that are performed by authorities.
not valuable at all
valuable to a degree
Data definition – Involvement
Data definition – Cost contribution
Date collection – Involvement
Date collection – Cost contribution
Data transformation – Involvement
Data transformation – Cost contribution
Data exploration – Involvement
Data exploration – Cost contribution
Data dictionary – Involvement
Data dictionary – Cost contribution
Granularity – Involvement
Granularity – Cost contribution
Architectures – Involvement
Architectures – Cost contribution
Governance – Involvement
Governance – Cost contribution
Other – Involvement
Other – Cost contribution
A push approach
Under a push approach, the reporting institutions will remain responsible for the data they sent, the explanation they provide regarding these data, the monitoring and updating of their own internal reporting process. This will contribute to the quality of the data
While under the push approach, the reporting institutions will oversee the transformation of the data they sent, transformation rules should be clearly defined jointly between authorities and reporting institutions.
Harmonization of the reporting requirements
Compliance with the General Data Protection Regulation (GDPR)
Definition of protocols between authorities to enhance sharing data among themselves to contribute to the reuse of data and avoid duplication of same data.
as supervisors will be able to do all sorts of aggregations and drill downs with the extracted data, reporting institutions will need to be able to know what type of queries or aggregations have been extracted, for example to replicate what supervisors have done and to be in capacity to answer to supervisors to any questions raised. Therefore, the responsibility of defining the transformation rules from granular data to templates must be exercised jointly by the authorities and the reporting institutions under a Joint Committee where reporting institutions could bring their technical expertise.
While the suggested coordination mechanism for data requests has many benefits, we would like to highlight the following points:
• A common data dictionary with consistent definitions applicable to a large scope of data requested, i.e. statistical, prudential, resolution should be a prerequisite.
• A joint committee as a forum of authorities should be completed with the participation of the reporting institutions, in particular for the definition of the transformation rules from granular data to templates where the participation of reporting institutions would provide technical expertise. It is important as the responsibility of defining the transformation rules from granular data to templates must be exercised jointly by the authorities and the reporting institutions.
• Authorities must enhance data sharing among themselves.
• National and ad hoc requests should be limited to specific reporting to treat specific situations or activities. To avoid additional costs for reporting institutions to collect more granular data with persistent ad hoc requests and no burden reporting relief, we believe that a clear commitment of the authorities is needed to issue fewer ad-hoc requests and to reuse more the granular data they already receive.