Generally clear, but some aspects require clarification - see detailed response
No - see detailed response. We disagree that fraud-related credit boundary events should be classified as pure" operational risk events. There are many other types of credit-related losses where operational risk, rather than credit risk, is the "source" of the credit position (e.g. failures in collateral management). It is important that all credit boundary events are properly captured within the scope of operational risk and subject to the same qualitative operational risk management framework; however, it is appropriate to model the associated capital requirements consistently within credit risk. Unable to find Article 48"
No - see detailed response. Including opportunity costs/lost revenues in operational risk event data should not be a requirement. Such information is highly subjective, would be costly to collect and would be of negligible value.