29.1.2024 - Summary of minutes

Place: Bank of Finland / Microsoft Teams

Present: Officials of the Bank of Finland (BoF). Industry representatives from the Savings Banks Group, OP Financial Group, ALM Partners and Aktia.

1. Update from the ECB

  • Central banks within the European System of Central Banks have to assess the costs and benefits of IReF requirements in euro terms in the ECBA cost survey
    • This is a so-called interim survey, which will be repeated in about a year.
    • The industry may also choose to participate in the survey through the EBF, which also responds to the survey.
  • The EBA (European Banking Authority) and the ECB have established a Joint Bank Reporting Committee (JBRC).

2. Analysis of responses to the cCBA

  • Split of outstanding nominal amount
    • According to industry participants present in the small working group, splitting is not a problem, since the components of outstanding nominal amount are available separately in the systems
    • This issue will certainly be discussed in more depth in the course of the IReF preparations
  • Tracking of internal instrument identifiers
    • Changes to internal instrument identifiers are currently prohibited in the AnaCredit data collection.
    • There is support for removing this requirement in the IReF and incorporating the tracking of these changes into the IReF systems.
  • Attributes related to climate change
    • There is consensus about the importance of the matter and the need for tracking
    • However, the costs are generally high
    • Nevertheless, there is support for collecting the address and 4-digit industry code
  • Collection of protection allocated values under the CRR
    • Collection of this data on a quarterly basis could reduce costs
  • Collection of governing law of loan agreements
    • It looks like this attribute will not be collected.
  • Collection of protection issuer and value
    • Collection of the issuer is still examined
  • Collection of non-IRB PD values
    • Other PD values than those generated by an IRB model could also be collected if the type of PD value is reported separately.
  • Manner of data submission
    • Resubmission of the whole report in the event of revision is considered the best practice.
  • Reporting schedule
    • A schedule with two monthly submissions and one quarterly submission is considered the most sensible.
  • Early submission of counterparty reference data
    • According to the proposal, this data should be reported concurrently with the reportable balance sheet data.