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The Draft AnaCredit Regulation needs to be assessed in conjunction with, firstly, the European Reporting Framework (ERF) and the Banks’ Integrated reporting Dictionary” (B.I.R.D.), two projects to which AnaCredit is intrinsically linked and, secondly, the efforts which the central banks and/or National Central Credit Registers of various Member States are currently undertaking to set up in parallel a similar framework for the collection of granular credit and credit risk data with a view of serving their domestic information needs.
The European Banking Federation (EBF) has long made called for an “integrated” reporting system which would align the various reporting streams to which banks are subject. When imposing new reporting requirements, public authorities have too often been focusing only on their specific information needs, without examining to what extent other public authorities have imposed identical or similar requirements. Clearly, such an outcome is not in line with the “single point of entry” principle: banks should be asked to report every piece of information only once, the understanding being that authorities would share the relevant data with each other subsequently to ensure that duplicating reporting requirements be eliminated. As such, the new ERF which the ECB aims to develop in the years to come is precisely meant to achieve such an alignment. More particularly, the ERF aims at building a framework which would allow banks to generate, on the basis of transaction level data which are available in their operational systems, reports to various authorities in a highly automated and integrated way.
The main merit of the proposed new framework is that it adopts an integrated approach which has the potential of achieving a reporting system that is aligned with the single point of entry principle. Such a new framework is likely to enhance efficiency and, as a result, of producing cost savings both to the industry and to the public sector.
The new approach will also allow banks to obtain a clearer view on reporting requirements. Furthermore, it may contribute to improving rulemaking considering that regulators will achieve a better understanding of how they need to describe what they wish to achieve.
Draft regulation of the ECB on the collection of granular credit and credit risk data