Question ID
2019_4920
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Operational risk
Article
324
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
5(2)
Type of submitter
Credit institution
Subject matter
Inclusion (or not) of a particular "timing loss" in the C 16.00 and C 17.00 template
Question

Shall a particular "timing loss" in the Operational Risk Losses be included or not in the reporting template for operational risk?

Background on the question

The question is related to the application of the Final Draft RTS on AMA Assessment and of the Regulation 680/2014 regarding the reporting of a particular Operational Risk Losses.

We consider a case where a Bank discovers that for a number of years there has been an erroneous calculation in deposit interest, for a specific product, resulting in crediting more interest than initially defined according to the product specifications to specific client deposits. The event occurred during the life of the product and spanned over several years. As a result of the above, the Bank’s profit and loss account would have been charged with a higher amount of interest expenses than it should have according to the Banks pricing policies on deposits. Due to the complexity of the case, the Bank would estimate the approximate amount of excessive interest paid to clients over the years, using specific assumptions and restrictions. A decision would also need to be taken as to the recovery of the excess interests credited to the clients’ deposits.

Submission date
Rejected publishing date
Rationale for rejection

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Status
Rejected question