The reporting requirements that AnaCredit entails will impose both high initial implementation and high running costs on institutions and IT providers. Thoroughness should have a precedence over speed, and the involvement of the banking industry should not be limited to the merit/cost analysis phase. We would therefore propose an ongoing involvement of the banking industry and IT providers in further activities on the basis of consultations. Such an approach has already amply proved its worth with the other standard setters in the area of banking regulation (i.a. EBA, NCAs).
While the initial investments by banks to improve their IT systems and reporting practices will certainly be very relevant, we have no certainty that this will be offset by lower running costs. At the very least there should be fewer ad hoc data requests from central banks.
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