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Die Deutsche Kreditwirtschaft // The German Banking Industry Committee

Additional Comments - general:
Implementation period
The EBA envisages an implementation period of one year after publication of the final ITS. This period is much too short. An adequate implementation period is at least one year from publication of the final Reporting Regulation in the Official Journal of the EU.

Operational Risk
In should be made clear on page 16 of the draft Regulation (PDF version) that there should continue to be no requirement for LSIs which use BIA to report OpRisk details and OpRisk losses and that institutions should be given the option of submitting the reporting templates voluntarily. At best, Article 5 b) 2 d) should be reworded so that there is no reporting requirement for LSIs which calculate operational risk in accordance with “Chapter 2 of Title III of Part Three of Regulation (EU) No 575/2013”.
Frank Mehlhorn
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