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STS441 Olivia H.

                         The integration of micro-data sets into a macro-
                                 prudential regulatory landscape,
                             exemplified by the AnaCredit regulation
                                            Olivia Hauet
                                    Nordea Bank, Stockholm, Sweden

            Abstract
            By introducing the AnaCredit regulation, the European Central Bank (ECB) has
            taken the concept of data-driven regulatory reporting to an unprecedented
            level. In addition to an ever-increasing burden of traditional template-based
            reports serving both supervisory and statistical purposes, credit institutions of
            the  Euro  area  are  requested  to  deliver  micro-data  on  a  loan-by-loan  and
            borrower-by-borrower level on a monthly and quarterly basis. The data are
            compiled  according  to  precise  definitions  and  organised  into  an  entity-
            relationship model.
            This  innovative  approach  to  data  collection  within  the  banking  sector  is
            premised on the following principles: any aggregated data can be obtained
            from granular data, but the reverse is not true – granular data enabling both
            drill-down and roll-up analysis; in order to be comparable, data need to be
            harmonised and standardised by way of common definitions and standards;
            data are of better quality when they are organised in a model reproducing
            business reality and input systems to the extent possible; top-down indicators
            calculated from granular data are not necessarily known in advance as new
            indicators  can  emerge  from  correlations  observed  between  the  underlying
            data.
            Ultimately, this approach should alleviate the reporting burden put on credit
            institutions since new macro-prudential indicators will be possible to compute
            from already collected data. In the longer term, and to the extent that rules for
            data dissemination across the national and European authorities allow, it could
            also establish a bridge between statistical and supervisory needs.
            This article explores, by illustrative examples, how some of the caveats of the
            AnaCredit regulation, from its conception to its application, may impede the
            fulfilment of its double objective, with regards to the collection of high-quality
            granular credit data across the Euro area and to the reduction of the reporting
            burden. It concludes by the necessity to break the remaining silos within banks
            but also within national and European authorities, and to pursue the work
            initiated on a larger scale, through initiatives such as the Banks’ Integrated
            Reporting Dictionary (BIRD) and the Integrated Reporting Framework (IReF).

            Keywords
            granular data, credit data, standardisation, data model, data dictionary


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