Response to consultation on ITS amending Implementing Regulation (EU) No 680/2014 with regard to operational risk and sovereign exposures

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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]

Additional Comments - general:
Implementation period
The EBA envisages an implementation period of one year after publication of the final ITS. This period is much too short. An adequate implementation period is at least one year from publication of the final Reporting Regulation in the Official Journal of the EU.

Operational Risk
In should be made clear on page 16 of the draft Regulation (PDF version) that there should continue to be no requirement for LSIs which use BIA to report OpRisk details and OpRisk losses and that institutions should be given the option of submitting the reporting templates voluntarily. At best, Article 5 b) 2 d) should be reworded so that there is no reporting requirement for LSIs which calculate operational risk in accordance with “Chapter 2 of Title III of Part Three of Regulation (EU) No 575/2013”.

Name of organisation

Die Deutsche Kreditwirtschaft // The German Banking Industry Committee