Response to consultation on Implementing Technical Standards on public disclosures by institutions of the information on operational risk
Question 1: Are the amended/new templates EU ORA, EU OR1, EU OR2 and EU OR3 and the related instructions clear to the respondents? If no, please motivate your response.
Frequency of operational risk disclosures.
We would like confirmation that templates OR1 and OR2 are published on an annual basis. Article 446 of the CRR3 referenced for OR1 and OR2 is not cited in the derogations from annual disclosures in article 433 a) of CRR3 relating to quarterly and half-yearly publications.
Question 2: Do the respondents identify any discrepancies between these templates and related instructions and the calculation of the requirements set out in the underlying regulation?
Decorrelation between templates C17.01 and C17.02 and template OR1 on operational risk losses.
As acknowledge by the EBA, we would like to point out that templates C17.01 and C17.02 will be maintained based on the current method, whereas the template OR1 in pillar 3 is moving towards a view of losses on operational risk in accordance with CRR3.
C17.01 and C17.02 will be adjusted once all the ITS texts (level 2) have been published. There will therefore be a decorrelation between the Pillar 3 publication (template OR1) and the supervisory reporting (templates C17.01 and C17.02) on this subject.
Question 3: Do the respondents agree that the amended draft ITS fits the purpose of the underlying regulation?
We have no comments.
Question 4: Do the respondents consider that the “mapping tool” appropriately reflects the mapping of the quantitative disclosure templates with supervisory reporting templates?
We have no comments.