Response to consultation on Implementing Technical Standards on supervisory reporting concerning operational risk
Question 1: Are the instructions and templates clear to the respondents?
One point is not fully clear with regards to “the reporting of grouped losses”. While definitions of grouped losses and aggregated losses have been added in CRR3, the CP (point 42 in section 3.2) indicates that reporting as a group is no longer applicable, but report will have to be done according to the impact in accounting. Hence this would mean that an event which generates several impacts below the reporting threshold in C.17.01 / C.17.02 is either not to be reported anymore (if each impact is below the reporting threshold) or not to be reported as an event higher that a defined threshold (eg. loss over EUR 100k) but rather reported as several events with different impacts.
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?
Except for the reporting of loss data where the rationale for not reporting according to the requirements set out in the regulation is explained, the templates and instructions seem to be aligned.