ANACREDIT : New reporting manual and guide to validation checks by ECB
Are you in scope? Are you ready?
ECB published on August 10th the first set of Q&A on the reporting manual (click here) along with a data validation checks guide (click here) explaining the main set of validation checks that will be performed in order to ensure that the data quality required for transmission to AnaCredit is sufficient.
Who is in scope?
The population impacted by the regulation is described in the article 3 of the regulation and includes both the credit institutions and its foreign branches, provided they are resident of a euro Member State.
In its explanatory note, the ECB confirms that the scope of the data collection covers data on credits extended or serviced by:
- credit institutions located in the euro area that are not branches of other credit institutions
- foreign branches of euro area credit institutions, including non-euro area branches;
- foreign branches that are located in the euro area but are part of a credit institution resident outside the euro area.
- non-euro area banking institutions as selected non Eurozone member states are expected to join Anacredit in 2018
What type of data should be reported?
AnaCredit will require over 100 data points to be reported for each exposure in the scope. Those data points cover many aspects of the exposure, including - data related to the counterparty (e.g. LEI code, address, number of employees, balance sheet total, etc.) - data related to instrument (e.g. type of instruments, currency, non performing status, interest rate type, payment frequency, etc.) - data related to the collateral or other mitigation techniques (e.g. type of protection, real estate collateral location, original protection value, etc.) or - accounting data (e.g. accumulated impairment amount, source of encumbrance, status of forbearance and renegociation, etc.).
What is the timeline?
31 December 2017: NCBs allowed to request the Anacredit dataset from credit institutions (early adoption)
30 September 2018: First complete AnaCredit reporting
How can Deloitte help you?
- conducting data gap analysis to ensure availability and accessibility of future data points required by AnaCredit
- ensuring alignment with other prudential reporting requirements (FINREP/COREP) and other regulatory requirements (IFRS9, BCBS 239)
- supporting the adequate inclusion of Anacredit in the Finance and Risk IT infrastructure, including tool selection process, custom solution development