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How EY can help
Along the end-to-end COREP reporting process, banks potentially encounter various challenges in their credit risk reporting (C.07 and C.08), as highlighted below, that might lead to incorrect reporting:
Inaccurate bifurcation and reporting of exposure classes: In the COREP reporting, sectoral classification of exposures plays a major role in RWA calculations. Customers are bifurcated based on exposure classes and credit ratings for the purpose of regulatory reporting. To ensure high quality and accurate reporting outputs., it is important to conduct periodic (say yearly) validation checks (through useful tools and enablers) of the detailed reference data tables across regions and legal entities.
Inappropriate allocation and access of credit limits: One of the major challenges faced by banks is the lack of adequate controls to capture credit limits accurately across group entities for a particular customer. To combat this situation, it is required to set up an operating model that facilitates consistent data lineage across regions to capture the overall credit limit of a customer at the group level. The group can achieve the same through a coordinated attestation process from all the regions to validate and confirm the credit limit for a customer.
Use of the same collateral against multiple exposures: Often, lack of a synchronous coordination between different business units leads to the origination of multiple exposures against the same collateral, leading to operational redundancies and duplication of efforts from a reporting standpoint. Therefore, it is required that the banks’ operating model involve collaboration within business units (BU) where different teams have the visibility of respective business activities of the customer through a centralized collateral management system. The same will help avoid redundancies, which could lead to incurring additional risk for the bank.
EBA validations: Extensible Business Reporting Language (XBRL) is a specific filing requirement for submission of the EU COREP returns to the regulators. Presence of a control and governance framework that involves robust controls such as four-eye checks, creation of EUCs, a centralized adjustment matrix with visibility of adjustments posted for various business functions and maintaining strict access controls will influence robust reporting.
Partial Permanent Use and Sequential Implementation: Firms that are eligible to avail the PPU exemption must have exposures only in non-significant business units and the types of exposures must be immaterial in terms of size and risk profile. Lack of adequate skilled resources in drafting requisite policies for regulatory approvals could pose a challenge for firms. Therefore, maintaining granular data dashboards on exposures subject to standardized and IRB approaches could be beneficial for firms to monitor any movement of its exposures from one approach to another.