The EACB welcomes the opportunity to comment on this set of EBA draft technical standards on the new requirements for the calculation of the Business Indicator under the new Operational Risk framework.
We appreciate the EBA’s efforts to clearly outline the components of the Business Indicator (BI). However, we see that several elements should be better aligned with the level 1 text. We also would like to note that with regard to template OR1, the mapping to supervisory reporting is not provided yet, it would be helpful for institutions to understand whether EBA is planning to establish such correspondence and by when.
We also recommend several clarifications regarding:
- The composition of the asset component and of the dividend component;
- The application of certain elements within an institutional protection schemes;
- The calculation of the financial component with respect to the use of accounting standards, the prudential boundary approach, the combination of approaches in a group, the notification process;
- The mapping to FINREP.