Response to consultation on Implementing Technical Standards on supervisory reporting concerning operational risk
Question 1: Are the instructions and templates clear to the respondents?
In general yes. In special cases there are no exact definitions to the instructions.
example: the outsourcing fees paid for the supply of non-financial services should be excluded from the Business Indicator
In C16.02 r0380 OUTSOURCING FEES that were paid for the supply of FINANCIAL service separately in administrative expenses in Finrep 02_ c0010 r 0360 /0380 should be included. What is exactly the definition of financial services? In the BCBS "Basel III: Finalising post-crisis reforms" from December 2017 it is stated on p. 135 that non-financial services (eg logistical, IT, human resources) should not be included in "fee and commission expenses" and thus not be included in the BI. Should all IT connected services, even if necessary to execute a financial service, be excluded?
Question 2: Do the respondents identify any discrepancies between these templates and instructions and the calculation of the requirements set out in the underlying regulation?
NA
Question 3: Do the respondents agree that the amended ITS fits the purpose of the underlying regulation?
NA
▪ specify which element(s) of the proposal trigger(s) that particularly high cost of compliance
NA
▪ explain the nature/source of the cost (i.e. explain what makes it costly to comply with this particular element of the proposal) and specify whether the cost arises as part of the implementation, or as part of the on-going compliance with the reporting requirements
NA
▪ offer suggestions on alternative ways to achieve the same/a similar result with lower cost of compliance for you
NA
Question 5 - Do you agree that proposed instructions and templates reflect in this draft CP cover all the clarifications needed from existing Q&As on operational risk reporting and those Q&As should be archived (as explained in Section 3.3)? If not, please refer to the Q&A number when explaining.
NA