How should a positive or negative loss adjustment be reported in template C 17.00 of Annex I of Regulation (EU) 680/2014 (ITS on Supervisory Reporting)? In particular, how should it be reported in the loss-size buckets (rows 920 – 924 of the template)?
A loss adjustment could be assigned to the loss-size buckets based on
a) the original loss amount before the adjustment
b) the cumulative loss amount after the adjustment or
c) the amount of the loss adjustment itself (positive or negative).
Without clarification on the applicable approach, institutions across the EU will report incomparable figures.
Please consider the following example, which follows option b) above:
Year t: Initial loss of 500,000
Year t + 1: Loss adjustments
i) + 60,000 → loss-size bucket ‘>=100,000 and <1,000,000’ (row 923)
ii) + 600,000 → loss-size bucket ‘>=1,000,000’ (row 924)
iii) – 450,000 → loss-size bucket ‘>=20,000 and <100,000’ (row 922)
iv) – 495,000 → no suitable loss-size bucket
v) – 500,000 → no suitable loss-size bucket
Independent from the assignment of the loss adjustment to a dedicated loss-size bucket, the amount of the loss adjustment would always be reported in row 920 as part of the total loss amount. Validation rule v3761_s would have to be amended or disabled to allow this kind of reporting.
A loss adjustment of an operational risk event has to be reported in the row for the total loss amount (row 920 of template C 17.00 of Annex I to Regulation (EU) No 680/2014 – ITS on Supervisory Reporting) and, where relevant, in the loss-size-based bucket pertinent to the cumulative loss of that event (option b above). The number of events is not affected by the reporting of loss adjustments.
Furthermore, paragraph 135 of chapter 4.2 of Annex II to the ITS on Supervisory Reporting explains that, in case of a negative value for some business lines/event types combinations, the values reported in the template shall be floored at zero. Thus, there is no need to change validation v3761_s.