Submission #37

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1) Please explain which institutions you think should be considered by the Feasibility Study.

All entities as considered in the regulatory scope of consolidation for any purpose of prudential authorities.

General remarks:
Initiatives that lead to a reduction in the reporting burden for institutions are very welcome.

The common data dictionary, central data collection point and improved exchange of reported data between authorities ("report once") mentioned in the EBA discussion paper can make a significant contribution to this goal. However, the concrete implementation in the regulatory framework based on the final EBA report expected at the end of 2021 remains to be seen.

The inventory of multiple reporting mentioned in several places in the EBA paper should lead to the elimination of these duplicate reporting requirements in a second step in the respective legal acts. The most effective way to reduce the burden on institutions in the area of reporting is to remove reporting requirements for institutions in the Level I texts and in the delegated acts without replacement. Even the Commission, in its fitness check of the EU supervisory reporting system, came to the conclusion that not every single one of the existing reporting obligations should (continue to) be necessary. Any reporting burden must always be balanced by a concrete, measurable and proportionate benefit.

Moreover, we argue for a thorough cost/benefit analysis and where possible one should build on already existing structures, in order to keep costs reasonable. An integrated reporting system must entail a clear benefit for both competent authorities and the industry. It must enhance efficient data sharing between all involved authorities in order to lessen the burden of data submission for banks.

2) Please explain which data collections you think should be considered by the Feasibility Study.

Like in Answer 1 we prefer a comprehensive approach covering the requirements of prudential authorities (EBA, SRB, SSM, ESZB Statistics, BIZ, national central banks und supervisory authorities etc.)

3) Do you consider that the issues identified, the options proposed and the assessment approach taken throughout the discussion paper are relevant and complete? If not, please explain.

The scope is comprehensive and can be used as a starting point for a discussion with the industry.

4) What do you perceive as the key obstacles and operational challenges to develop an integrated Reporting Framework (for your institution)?

	Not relevant	Somewhat relevant	Relevant	Highly 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

5) Do you confirm the findings presented in the stocktake? If you have additional information, please provide more specific details about the amount of data collected. yes

6) Do you agree on the holistic approach used and the assessment done for the integration assessment (different steps of the reporting process chain and different levels of integration?

	Highly agree	Don’t agree
Data Dictionary - Semantic level	X
Data Dictionary - Syntactic level		X
Data Dictionary - Infrastructure level		X
Data collection - Semantic level	X
Data collection - Syntactic level		X
Data collection - Infrastructure level		X
Data transformation - Semantic level	X
Data transformation - Syntactic level		X
Data transformation - Infrastructure level	X
Data exploration - Semantic level	X
Data exploration - Syntactic level	X
Data exploration - Infrastructure level	X

8) Do you use one or more data dictionaries in your compliance and reporting processes?

For internal purposes we have an internal data dictionary and for external reporting we have to use a predefined data model from the Austrian National Bank. The respective data model from the Austrian National Bank considers also a reporting layer.

9) What are the characteristics you think a data dictionary should have? Do you agree with the one referred to in this document? Do you think any characteristic is missing or should not be included?

The data dictionary should at least consider the input and output parameters incl. transformation logics to ensure data linage.

10) What is the role you think the data dictionary can have in regulatory compliance and reporting? Business dictionary/ definition of terms in business language.

11) How much would a standard data dictionary help institutions to improve the processes of:

	Significantly	Moderately	Low
Understanding reporting regulation	X
Extracting data from internal system		X
Processing data (including data reconciliation before reporting)			X
Exchanging data and monitoring regulators’ feedback		X
Exploring regulatory data	X
Preparing regulatory disclosure compliance.	X
Other processes of institutions	X

12) How important is it for institutions to have a unique and standard data dictionary for all regulatory data with the aim of ensuring consistent use across the supervisory, resolution and statistical reporting? Highly important

13) How much would it cost to move to a unique regulatory data dictionary? Highly costly

14) How much cost reduction is expected by integrating the national regulatory reporting together with the harmonised reporting regulation into a unique data dictionary? Moderate cost reductions

15) How much cost reduction is expected by integrating ad hoc regulatory reporting with harmonised regulation into a unique data dictionary? Small cost reductions

16) Do you agree with the costs and benefits highlighted in the chapter? Do you see other costs and benefits when implementing a standard data dictionary? It depends on the lifetime of existing IT systems in the bank

18) For which reporting areas (prudential, statistical and resolution or modules/parts of these areas) may the use of granular data present a solution? (multiple choices)

statistical
resolution
prudential

Feasable and preferable

20) In case of Option 2, please specify how should the granular collection layer be designed to your best advantage (and benefit of reporting more granularly)? Currently not applicable

Costs

	Highly (1)	Medium (2)	Low (3)	No costs (4)
Collection/compilation of the granular data	X
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 resources	X
Human resources	X
Complexity of the regulatory reporting requirements	X
Data duplication	X
Other: please specify	X

benefits

	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 specify	X

23) If transformations are to be defined (as depicted in Option 2 or Option 3), who should be responsible for their definition (e.g. who takes responsibility for their correctness) and their execution?

25) How should the transformations be in terms of formalisation and readiness for digital processes?

27) What kind of data should be part of the feedback loops? Principle of confirmation of anchor values should be followed.

29) Is your institution reporting to different authorities in your home country? Yes

30) Is your institution reporting to other authorities in host countries? Yes

Please comment: What problems arise from reporting to different authorities?

Different local specifics/definitions that cause differences that are challenged by the authorities.

31) Are you using one or more data dictionaries for reporting? How? Multiple dictionaries

32) Are you using the same or different formats for prudential/resolution reporting and for statistical reporting? Different formats

33) How important would it be, for your institution, to have access to a CDCP for all prudential, resolution and statistical reports? Why? Important

37) Would the industry be prepared to bear the costs of integrated reporting? Yes, to a limited extent

38) Where (within the different elements discussed in the paper) do institutions and CAs see institutions’ involvement and cost contribution as most valuable in the development of an integrated reporting framework?

	not valuable at all	valuable to a degree	highly 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 – Involvement		X
Granularity – Cost contribution		X
Architectures – Involvement	X
Architectures – Cost contribution	X
Governance – Involvement			X
Governance – Cost contribution			X
Other – Involvement
Other – Cost contribution

40) Would you prefer the future integrated reporting system to be based on: A push approach

Collection and access to granular data by authorities Possible solutions
GDPR
IT security

The responsibility of the reporting institutions for the reported data, if the transformation of granular data is conducted by authorities (i.e. not the reporting institution) Possible solutions
Transparency
Lineage

48) Are you making use of RegTech for reporting purposes? If yes, please tick for which reporting process step:

Data collection
Data transformation
Data exploration

If no, please explain:

49) Which of the reporting process steps would benefit more from RegTech development? Data collection

50) Do you agree with the main obstacles highlighted in the discussion paper? Do you see any further challenges? Partially

51) Would you be keen to invest in RegTech for integration of different types of data? How would you develop such a technology? via a service provider

52) How do you think RegTech can help in data integration?

By having data transformation and connecting data points with underlying regulatory requirements.

53) Do you agree that data standardisation is the first necessary step for using RegTech? Yes

Contact name Dr. Franz Rudorfer

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