Response to consultation on Regulatory Technical Standards on operational risk loss

Question 1: Do you think that the granularity of and the distinction between the different Level 2 categories is clear enough? If not, please provide a rationale.

Please refer to document attached.

Question 2: Do you perceive the attribute “greenwashing risk” as an operational risk or as a reputational risk event? Please elaborate.

Please refer to document attached.

Question 3: To which Level 1 event types and/or Level 2 categories would you map greenwashing losses? Please provide a rationale.

Please refer to document attached.

Question 5: Which of these attributes do you think would be the most difficult to identify? Please elaborate.

Please refer to document attached.

Question 6: Do you agree with the inclusion of the attribute “Large loss event”? If not, please elaborate.

Please refer to document attached.

Question 7: Do you think that the granularity the proposed list of attributes is clear enough? Would you suggest any additional relevant attribute? Please elaborate your rationale.

Please refer to document attached.

Question 8: Would it be disproportionate to also map the three years preceding the entry into force of these Draft RTS to Level 2 categories? If yes, what would be the main challenges?

Please refer to document attached.

Question 11: Which of the provisions of Article 317(7), as developed by the draft RTS on the development of the risk taxonomy, and Article 318 of the CRR would be most difficult to implement after a merger or acquisition for the reporting entity? Please elaborate.

Please refer to document attached.

Question 12: In your experience, would the provisions of this article apply to most mergers and acquisitions, or would data usually be promptly implemented in the loss data set of the reporting institution?

Please refer to document attached.

Question 13: Are there other adjustments that should be considered in these draft RTS? If yes, please elaborate.

Please refer to document attached.

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