Response to consultation on Regulatory Technical Standards on operational risk loss
Question 7: Do you think that the granularity the proposed list of attributes is clear enough? Would you suggest any additional relevant attribute? Please elaborate your rationale.
While the granularity appears clear enough it should be said that any further attributes added represents additional work during the documentation and processing phase of operational risk events and may therefore negatively affect the quality of documented operational risk events.
Question 8: Would it be disproportionate to also map the three years preceding the entry into force of these Draft RTS to Level 2 categories? If yes, what would be the main challenges?
Concerning the new CRR III Level 2 categories the main problem of categorising the three years preceding once this Draft RTS enters into force would be the correct mapping of the old Level 2 and Level 3 categories onto the new CRR III Level 2 categories.
In general, but especially so if Institutions will be required to map risk events of preceding years onto the new categories, the EBA should provide a mapping key which shows how the former Level 2 and 3 categories are to be mapped onto CRR III Level 2 categories. A uniform mapping key is a vital requirement to keep a high level of comparability of operational risk events across the banking sector as otherwise differences might occur in the mapping of the categories.