FBF comment on the draft ECB Regulation on the collection of granular credit and credit risk data

The French Banking Federation (FBF) represents the interests of the banking industry in France. Its membership is composed of all credit institutions authorized as banks and doing business in France, i.e. more than 425 commercial, cooperative and mutual banks. FBF member banks have more than 39,000 permanent branches in France. They employ 380,000 people in France and around the world, and service 48 million customers.

The French Banking Federation welcomes the opportunity to express the views of the French banking sector on the Draft Regulation on the collection of granular credit and credit risk data (“AnaCredit”).
We welcome the process to submit observations organised by the ECB regarding the AnaCredit Draft Regulation in order to collect views of the involved stakeholders. We also welcome that the Draft Regulation deals only with the loans granted to legal entities. For the sake of clarity and optimization of implementation costs, banks need a stable and predictable statistical reporting environment that would not be subjected to frequent amendments. Indeed, banks currently modify their IT systems (reporting and source systems) but also review their internal reporting and management processes to achieve implementation of international standards (i.e. IFRS 9) and new reporting requirements (i.e. new permanent and ad-hoc supervisory reporting, ECB FINREP regulation, Pillar 3 disclosures…). Accordingly, while the recitals of the Draft Regulation indicate that the AnaCredit project will be established in stages, we advocate that the further stages should also be submitted to observations and that a strong cost-benefit analysis should be completed.

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