The European Association of Co-operative Banks (EACB) members welcome the fact that the SRB Valuation Data Set relies, to some extent, upon existing common definitions used in reporting under the EU regulatory, supervisory and reporting frameworks and takes into account AnaCredit and other data sets already produced by banks.
We note that the ECB has a project of standardizing OSI loan tape requests, which touches upon very similar items as this SRB valuation data exercise. We hope there would be synergies and authorities would synchronize the data dictionaries as far as possible.
Taking into account the huge investments and IT changes this will require from banks, we would also highlight the following concerns:
- We think some data items are less relevant than others. We suggest relevance check leading to less important data fields to be possibly dropped out. There is no need to make expensive IT-changes, if not deemed absolutely necessary for valuation purposes. We would like to have a similar prioritization of data points/variables as in EBA´s Data Dictionary. This would provide a clear order of priority for all institutions. We would welcome a reasoning for each data point and how it is relevant for valuation, especially for variables that are not self-explanatory in respect of valuation relevancy.
- We understand the need for timely and high-quality data for robust valuation in case of resolution. However, we question whether the magnitude of data requested is necessary for valuation which could be done as well based on data on more aggregated level, for example based on regulatory reporting data. The valuation in resolution will be a stressful and rushed situation where millions of data points not necessarily make the proses smoother, but more complex.