Blog By: Saloni Ramakrishna, author and senior director, Oracle Financial Services Analytical Applications.
It depends on who is answering that question. Really!!
It is a single uniform regulation at the ECB (European Central Bank) level with clearly spelt our coverage. To ECB’s credit they have given comprehensive implementation information through the detailed AnaCredit Reporting manual, part 1, 2 and 3. The information that they expect from all the participating NCBs (National Central Banks) is uniform and that is what is detailed in the manual. They however add that there is room for some national discretion (National Arrangements as ECB refers) with the National Central Banks (NCBs) on how they collect that information from their constituents. National Central Banks, that need to adhere to the AnaCredit regulation, have or will have a single uniform regulation for their constituents.
Interestingly however, if you ask the banks and credit institutions that need to provide the required information in the required format and frequency, there would be two different answers.r Many? A look at the impact of National variations.
The critical point to be kept in context while discussing AnaCredit is that it is a two-step process as I spoke of in my previous blog. Step one is where Banks and Credit Institutions submit the Credit data sets across the 10 subject areas to their National Central Banks. Step 2 is NCBs submitting the data to ECB as required by the AnaCredit regulation (ECB refers to this as the “Baseline Scenario”). Note that I have not said the data NCBs receive from their constituents. And therein lies the plurality that regional and global banks will need to address.
Scope of National Arrangement areas per part 1 of the AnaCredit Manual issued by ECB (AnaCredit Reporting Manual Part 1 dated 9th November 2016) are
Whether NCBs decide to deviate from the “baseline requirements”, and to what extent, will be communicated by them. The moot question is what does all of this mean to Banks and Credit Institutions that have global or even regional operations? Short answer, it impacts all three aspects - content, timelines and the format of reporting and that is saying a lot. Some of the countries that have come out with their implementation guidelines like Germany, Netherlands, Belgium, France and Ireland point to the reality of national variations of the execution of AnaCredit regulation in different geographies.
All the above truly make the implementation of AnaCredit much more nuanced, requiring a well thought out inclusive functional and information policy and architecture. In my next blog, I will explore the “Regulatory hub” approach that the banks with multi country presence might want to consider so they can have a “Unity in Diversity” construct that can be leveraged not just for AnaCredit implementation but that which enables them to truly “use” and “reuse” their biggest asset – DATA to create business value.