On 08 April 2014, the European Central Bank (ECB) announced resolution ECB/2014/6, laying the foundation for the establishment of a new European central credit register. The far-reaching impact of the Analytical Credit Datasets (short form: AnaCredit) initiative will affect virtually all financial institutions. This ECB regulation was enacted on 18 May 2016 and published shortly thereafter. The resolution primarily concerns the provision of a wealth of information about the institution’s borrowers, the loans it has granted as well as the collateral for those loans, to the respective national central banks of member countries. The national central banks will then transmit this data to the ECB. This report must be provided in addition to the reporting requirements already in place. The regulation applies within the European Economic and Monetary Union.
- create a standardized European credit register
- allow for organized collection and administration of granular credit data
- gain an overview of debtors as well as the nature, amount, terms of loans granted in the Eurozone
- provide data to ECB for statistical and regulatory purposes as well as for monetary considerations
- monitor institutions via Single Supervisory Mechanism (SSM)
Requirements and standards for the institutions
The reporting requirement initially pertains exclusively to loans granted to legal entities. The reporting threshold is set at 25.000 € (based on the sum of all loans per borrower). Reporting for loans to private individuals will be not required in Phase I though it is expected to be required in future phases. Monthly reporting will be conducted for each and every individual loan dataset of affected borrowers via the German Central Bank to the ECB on a loan-by-loan basis. The master data information relevant to the report must be transmitted on a one-off basis or, in the event of changes, transmitted on an ongoing basis.
The 95 attributes currently required by the ECB can be broken down into the following categories:
- commercial data
- protection seller
- protection buyer
- knowledge of investment pools and debt ratios.
Implementation and anticipated timeline
The implementation will be carried out in several phases, starting with Phase I on 31 December 2017 (when the enactment takes legal effect). From that date on, the national central banks will initially be free to demand master data and amount data from institutions. The German Central Bank has already announced a test phase for the last quarter in 2017 which is preceding the first official report transmission. In this respect, the German Central Bank scheduled the delivery of master data "partner" starting on 31 January 2018 and credit data on 31 March 2018. The first transfer of master data "partner" to the ECB is scheduled for 31 March 2018. Any further phases remain yet to be defined and will not take legal effect any earlier than 2 years after their official ECB council order. The following graphic depicts the implications of each individual phase:
The greatest challenge for the affected institutions will be compiling the data from the various areas in question, for example risk management, lending, reporting, accounting, etc., and providing that data in the required levels of quality and granularity. For most institutions, current IT-architecture, existing data availability in the front office as well as current data warehouse processing will not be up to this task.
The following points provide an overview of the specific challenges in store for financial institutions:
- Comprehensive adjustments to systems and processes will be required. One must take full advantage of the narrow time window between identifying an approach and implementing it. This is especially true for procedural issues.
- Additional challenges will arise especially for financial institutions with foreign branch offices or subsidiaries in connection with national requirements and late group reporting.
- A variety of data suppliers are involved in procuring the required information. The role of creating a uniform database in doing so, partially from a variety of business areas, must not be underestimated.
- Significant improvements to data quality will be required due to the low reporting threshold.
- Manual corrections will not be possible due to the high data volume. Notwithstanding this, consistency with other reports must be ensured.
- Potential overlap with or implementation in connection with other projects (e.g. BCBS 239) should be examined.
In light of the narrow time window and stringent requirements, financial institutions must react quickly and conduct a gap analysis as soon as possible. Addressing these issues head on with appropriate project planning from the outset are the only means of ensuring suitable and timely implementation.
An Overview of our services
The SKS Group is here to support you with a preliminary study to identify gaps and fields of action relevant to implementing AnaCredit. We then provide expert and technical support via SKS Advisory and SKS Solutions in the course of an implementation project. Our approach has proven successful in delivering solutions for a great number of clients. More specifically, we provide the following services:
We’d like to refer you to an article by SKS in Risiko Manager magazine. You’ll find the article here.
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