Response to consultation on draft Regulatory Technical Standards on materiality threshold of credit obligation past due
Go back
• Whether the amount overdue is already available in data bases and systems used for RWA calculations as well as credit risk parameter and model recalibrations, or whether a tactical solution to determine this amount will be allowed by supervisory authorities. As stated above in Annex I, not all of the data will be initially available in the requisite form needed. This will require reengineering the interfaces and systems for example in the RWA calculation, credit risk parameters and model recalibrations. A retroactive adjustment of historical default and non-default data would be difficult and in some instances might not be possible.
• To meet the need to adjust default and loss data history to meet the draft RTS requirements.
• To work though the credit risk parameters and models that need to be validated and recalibrated to meet the requirements.
• The intensity and timelines of the supervisory approval process.
Q2. Do you agree with the proposed maximum levels of the thresholds?
Yes. However, rating system specific exceptions should still be possible, subject to supervisory approval. Additionally, DB is unclear why the Draft RTS defines these as maximum levels but still allows for national discretion.Q3. How much time is necessary to implement the threshold set by the competent authority according to this proposed draft RTS? Given current practices, what is the scope of work required to achieve compliance?
There are substantial implementation efforts that would be required. Please see Annex I section “Transitional period / Implementation efforts” for details. The length of time required is a result of four main factors.• Whether the amount overdue is already available in data bases and systems used for RWA calculations as well as credit risk parameter and model recalibrations, or whether a tactical solution to determine this amount will be allowed by supervisory authorities. As stated above in Annex I, not all of the data will be initially available in the requisite form needed. This will require reengineering the interfaces and systems for example in the RWA calculation, credit risk parameters and model recalibrations. A retroactive adjustment of historical default and non-default data would be difficult and in some instances might not be possible.
• To meet the need to adjust default and loss data history to meet the draft RTS requirements.
• To work though the credit risk parameters and models that need to be validated and recalibrated to meet the requirements.
• The intensity and timelines of the supervisory approval process.