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ESBG - European Savings and Retail Banking Group

Feedback received from some ESBG members suggests that the implementation costs of C17.01 would be 2 people/day, with recurring production costs of 0.5 people/day. These costs, members have opined, are similar to other requests like the SSM short-term exercise.
In relation to the costs of the new reporting template C17.02, members are less certain but estimate, without a large degree of confidence that it would result in similar costs.
ESBG members have stressed the importance of providing detailed examples illustrating how to fill the rows 930 to 934 (number of events subject to loss adjustments) and rows 941 to 944 (loss adjustments by size of the loss). From responses received it is also clear that there is a need for detailed examples to be provided on how to incorporate, in all templates, negative data, and how to manage the losses under the €10,000.00 threshold.
The assessment of the current text is that it leaves room for interpretation. In order to avoid ambiguities detailed examples for reporters on how to report different situations must be provided.
The view has been expressed by ESBG members that, both the risk of error and the costs of implementation outweigh the possible benefit of the proposed method of reporting loss adjustments. As with all new developments in these areas the substantial cost to the reporter must be justified by the benefit received.
Members are of the opinion that, regarding paragraph 139, options “a” and “b” are the least costly.
Sean Doyle
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