On 8th April 2014, the European Central Bank (ECB) announced resolution ECB/2014/6, laying the foundation for the establishment of a new European central credit register. The far-reaching impact of the Analytical Credit Dataset (short form: AnaCredit) initiative will affect virtually all financial institutions. This ECB regulation was enacted on 18th May 2016 and published shortly thereafter. The resolution primarily concerns the provision of a wealth of information about the institution’s borrowers, the loans it has granted as well as the collateral for those loans, to the respective national central banks of member countries. The national central banks will then transmit this anonymized data to the ECB. This report must be provided in addition to the reporting requirements already in place. The regulation applies within the European Economic and Monetary Union.
- create a standardized European credit register
- allow for organized collection and administration of granular credit data
- gain an overview of debtors as well as the nature, amount, terms of loans granted in the Eurozone
- provide data to ECB for statistical and regulatory purposes as well as for monetary considerations
- monitor institutions via Single Supervisory Mechanism (SSM)
Requirements and standards for the institutions
The reporting requirement initially pertains exclusively to loans granted to legal entities. The reporting threshold is set at 25.000 € (based on the sum of all loans per borrower). Reporting for mortgage loans to private individuals will be not required in Phase I (as of 23th May 2016) though it is expected to be required in future phases. Monthly reporting will be conducted for each and every individual loan dataset of affected borrowers via the German Central Bank to the ECB on a loan-by-loan basis. The master data information relevant to the report must be transmitted on a one-off basis or, in the event of changes, transmitted on an ongoing basis.
The 95 attributes currently required can be broken down into the following categories:
- commercial data
- protection seller
- protection buyer
- knowledge of investment pools and debt ratios
The German Central Bank is not expected to require reporting for attributes beyond those explicitly mandated by the ECB during Phase I. However, all national central banks within the European Monetary Union are free to mandate reporting of additional attributes as desired.
Implementation and anticipated timeline
The draft resolution from December 2015 provides for a brief observation period lasting until 29th January 2016 during which time comments can be submitted to the ECB. The final consultation and decision of the ECB’s Governing Council took place on 18th May 2016. Instructions from the German Central Bank based on the resolution in accordance with § 18 BBankG have yet to be provided. Implementation is expected to proceed in a number of phases, starting with Phase I on 31th December 2017. From that date on, the national central banks will initially be free to demand master data and amount data from the institutions. The German Central Bank has already announced a test phase that will precede the first report transmission. Current statements made by the German Central Bank are limited to advanced reporting of master data starting in the first quarter of 2018. However, it can’t be ruled out that this will be extended to cover amount data. At the moment it remains to be seen to what extent the German Central Bank will implement the ECB resolution in detail. The first transmission of the report to the ECB is currently scheduled for 30th September 2018. Though further phases have yet to be defined, the ECB will announce these at least two years in advance. The following graphic depicts the implications of each individual phase:
The greatest challenge for the affected institutions will be compiling the data from the various areas in question, for example risk management, lending, reporting, accounting, etc., and providing that data in the required levels of quality and granularity. For most institutions, current IT-architecture, existing data availability in the front office as well as current data warehouse processing will not be up to this task.
The following points provide an overview of the specific challenges in store for financial institutions:
- Comprehensive adjustments to systems and processes will be required. One must take full advantage of the narrow time window between identifying an approach and implementing it. This is especially true for procedural issues.
- Additional challenges will arise especially for financial institutions with foreign branch offices or subsidiaries in connection with national requirements and late group reporting.
- A variety of data suppliers are involved in procuring the required information. The role of creating a uniform database in doing so, partially from a variety of business areas, must not be underestimated.
- Significant improvements to data quality will be required due to the low reporting threshold.
- Manual corrections will not be possible due to the high data volume. Notwithstanding this, consistency with other reports must be ensured.
- Potential overlap with or implementation in connection with other projects (e.g. BCBS 239 and FinRep) should be examined.
In light of the narrow time window and stringent requirements, financial institutions must react quickly and conduct a gap analysis as soon as possible. A cost estimate for implementing the project appropriate to the institution’s structure should be made at an early stage. Addressing these issues head on with appropriate project planning from the outset are the only means of ensuring suitable and timely implementation.
An Overview of our services
The SKS Group is here to support you with a preliminary study to identify gaps and fields of action relevant to implementing AnaCredit. We then provide expert and technical support via SKS Advisory and SKS Solutions in the course of an implementation project. Our approach has proven successful in delivering solutions for a great number of clients. More specifically, we provide the following services:
- Pre study gap analysis Workshop
- Architecture Consulting
- Analysis of data requirements and identification of data sources
- Project managment and test Management
- IT implementation of requirements
- Specialist and DP conceptual designs
- Project planning and implementation support
We’d like to refer you to an article by SKS in Risiko Manager magazine. You’ll find the article here.
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