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The use of the Standardized Approach to calculate minimum capital requirements for operational risk should be decided by the Board of Directors or equivalent body of the credit institution. This decision should be notified to the Directorate General Banking Supervision of the Banco de España by the Managing Director or General Manager of the credit institution indicating that the criteria and requirements set in Circular 3/2008 are being complied with and that the Directorate General Banking Supervision has available to it the information set out in this document[2] and any information additional to that listed herein that may be considered relevant for the purpose of being able to assess compliance with the minimum requirements for using the Standardized Approach.
The information made available to the Banco de España should clearly distinguish between the state of implementation at the current time and the plans for envisaged improvements. The information should be made available preferably in electronic format and structured in the following sections:
A. Calculation of capital requirements
B. Mapping of activities and of Relevant Income
C. Other qualitative requirements
C.1. Senior management
C.2. Internal management structure
C.3. Operational risk loss database
C.4. Operational risk management system
C.5. Management information
C.6. Technological support
C.7. Independent review
C.8. Contingency plans
C.9. Internal assessment
A. Calculation of capital requirements
1. Group organisation chart. List of entities comprising it, with specification of their activity, hierarchical position and relative importance in terms of total assets, gross income, net income for the year and number of employees.
2. The entities and/or units included in the calculation of capital requirements under the Standardized Approach. For the entities not included, in which the Basic Indicator Approach will be applied, state the following:
a. evidence of compliance with the requirements set in point 10 of Rule ninetyfive, so as to be able to apply a combination of the two approaches
b. detailed roll-out plan for application of the Standardized Approach
3. Results of the calculation of regulatory capital requirements for operational risk.
Distribution among the various group entities.
B. Mapping of activities and of Relevant Income
4. Definition and description of internal business lines and mapping to the business lines defined in Circular 3/2008.
5. Definition and description of event types and assignment to those defined in Circular 3/2008.
6. Specific policies and criteria developed for the mapping of activities and of Relevant Income to business lines.
7. Justification of the role of senior management and management bodies in the mapping policies.
8. Any reviews conducted of those policies and criteria.
9. If management data has been used in mapping Relevant Income to business lines, evidence that the mapping procedures have been approved, documented, updated and integrated in internal management systems.
C. Other qualitative requirements
C.1. Senior management
10. Description and documentary support of the role of the Board of Directors and senior management in approval and periodic review of the management framework.
11. Corporate manuals on operational risk policies and procedures; date of latest update, persons responsible for drafting them and the bodies to which they were submitted for approval and when.
12. List of other internal documents considered significant, with a brief description of their content.
C.2. Internal management structure
13. Composition and functions of the areas, departments and committees involved in operational risk management, assessment and control, including also for the latter the periodicity of meetings and the date they were set up.
14. Composition and functions of the committees which, although not directly managing operational risk, may be related to it.
C.3. Loss database
15. Internal loss database file.
16. Description of:
a. Persons responsible for database input, maintenance and validation.
b. Automatic and manual data capture procedure.
17. Data quality and integrity control procedures carried out by the operational risk unit. Results of the latest tests.
18. Database analysis reports. Historical record and distribution of events by unit, business line and event type. Explanation of changes in and distribution of data.
19. Internal accounting plan. List of accounts fully or partially reflecting operational risk.
20. Register of significant reputational or business events excluded from the database.
C.4. Operational risk management system
21. Corporate tools used for operational risk management. Methodological and user’s manuals, date when last updated, persons responsible for drafting them and the bodies to which they were submitted for approval and when.
22. Implementation of corporate tools for operational risk management in the various group entities. For each entity, specification of the following:
a. units, areas or departments in which the tools have been implemented, with an indication of their relative importance within the entity in terms of operational risk (using gross income or, if this is not sufficiently informative, other items).
b. units, areas or departments in which qualitative management tools are not used, indicating why not.
23. Map of the entity’s level 1 processes.
24. Identification of the credit institution’s significant operational risk sources and the measures to assess exposure to the main types of events.
25. If qualitative internal risk assessment exercises have been carried out, give details of the internal procedures for the construction and quality control of internal assessments, the database of completed assessments and the timetable of envisaged exercises.
26. List and brief description of risk mitigation plans and recommendations that have been actually implemented and of those envisaged.
27. List and brief description of risk indicators implemented, and a risk indicator implementation timetable.
C.5. Management information
28. List of periodic and ad hoc reports addressed to business lines and to supporting activities, particularly those sent to senior management. Identification of their recipients and of the extent to which their preparation is manual or automated. Content and frequency of these reports.
C.6. Technological support
29. Description of the technological support, information systems and applications which enable the use of databases, management tools and risk assessment systems.
30. Description of internal controls and procedures in place to ensure the consistency and reliability of management system information sources, indicating who is responsible for these controls and the periodicity thereof.
C.7. Independent review
31. Description of the role of Internal Audit. List of reviews carried out and of their results, which should at least include the report with the content and structure given in Annex 2.
32. List of independent reviews or collaborations (external audit, consulting, etc.). Aims of them and conclusions drawn.
C.8. Contingency plans
33. List of emergency and business continuity plans of the credit institution.
34. Periodicity of the drills carried out. Results of the latest drills.
C.9. Internal assessment
35. Assessment of the degree of compliance with the current minimum qualitative requirements for eligibility for the desired approach, with an indication of the known weaknesses and the proposed timetable for remedying them.
36. List and implementation timetable of envisaged changes to and future development of the management system.
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In the case of credit institutions that are subsidiaries of foreign groups not subject to Directive 2006/48/EC of 14 June 2006 relating to the taking up and pursuit of the business of credit institutions, the subsidiaries themselves or, where applicable, the Spanish credit institution responsible for consolidation in Spain, should make this information available.
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