Response to consultation on Regulatory Technical Standards on operational risk loss

Question 1: Do you think that the granularity of and the distinction between the different Level 2 categories is clear enough? If not, please provide a rationale.

See the attachement

Question 2: Do you perceive the attribute “greenwashing risk” as an operational risk or as a reputational risk event? Please elaborate.

In general, we perceive the attribute “greenwashing risk” as a reputational risk but there may be some cases concerning operational risk 

Question 3: To which Level 1 event types and/or Level 2 categories would you map greenwashing losses? Please provide a rationale.

NA

Question 4: Is “Environmental – transition risk” an operational risk event? If yes, to which Level 2 categories should it be mapped? Please provide a rationale.

NA

Question 5: Which of these attributes do you think would be the most difficult to identify? Please elaborate.

In our opinion the  atribute Social risk is be the most difficult to identify. In general most operational events may affect employees/clients/counterparties. We are not sure which operational risk event should receive this attribute.

Question 6: Do you agree with the inclusion of the attribute “Large loss event”? If not, please elaborate.

NA

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.

See the attachement

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?

The most difficult task will be mapping historical data to the new level 2 categories. Will it be necessary to map historically all the attributes as well?

Question 9: Is the length of the waivers (three years and one year) for institutions that, post merger or acquisition fall into the EUR 750 million – EUR 1 billion band for the business indicator, sufficient to set up the calculation of the operational risk loss following a merger or acquisition? If not, please provide a rationale.

NA

Question 10: Are there other cases where it should be considered to be unduly burdensome for institutions to calculate the annual operational risk loss?

NA

Question 11: Which of the provisions of Article 317(7), as developed by the draft RTS on the development of the risk taxonomy, and Article 318 of the CRR would be most difficult to implement after a merger or acquisition for the reporting entity? Please elaborate.

NA

Question 12: In your experience, would the provisions of this article apply to most mergers and acquisitions, or would data usually be promptly implemented in the loss data set of the reporting institution?

NA

Question 13: Are there other adjustments that should be considered in these draft RTS? If yes, please elaborate.

Please adress our questions from the attachement

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