validation session for banks
TRANSCRIPT
Validation session for banks
12 September 2016
Programme
12 September 20162
9.30 – 11.00 1. Introduction
2. Objectives of validation session
3. Test reporting for banks
4. DNB validation process for supervisory reports
5. Taxonomy validations
6. Consistency and plausibility checks
11.00 – 11.20 Break
11.20 – 12.15 7. Other quality checks
8. Other matters
9. Rounding off and follow-up
12.15 Lunch
12 September 20163
• Word of welcome
• Why this validation session?
• Data quality is important for high-quality supervision
1. Introduction (1)
1. Introduction (2)
4
Data quality is not a specific topic in CRR/CRD IV as such…
but rather enforced by all the regulatory requirements defined in the CRR, CRD
IV and Regulation (EU) No 680/2014 (EBA ITS)
12 September 2016
2. Objectives of validation session
12 September 20165
• Informing banks of the new validation process for CRD-IV reports
effective from 1 October 2016
• Starting with the September 2016 reference period
• Focus on the process rather than XBRL technology
• Answers to banks' questions (submitted through the Dutch
Banking Association – NVB)
• Wishes and improvement proposals will be included in the CRAP
3. Test reporting for banks
12 September 20166
• The deadline for test reporting for banks was 9 September
• Almost all banks managed to complete the test successfully
• Additional test reports submitted after a successfully completed
test will not be processed
• Cleaning up the environment in preparation of implementation on
1 October
4. DNB validation process for supervisory reports
12 September 20167
Consistency and
plausibility checks
Taxonomy validations
ReceivalOther quality
checks
• DNB validation process flow chart
• Validations and checks will be discussed for each of the process
steps
• In due course, this validation process will also be applied to other
taxonomy-based reports submitted through the DLR portal
• Feedback from EBA and ECB are included as a regular part of
DNB validation process
Use of data by Supervision divisions
5. Taxonomy validations (1)
12 September 20168
Taxonomy validations include:
• Filing rules
• Taxonomy validation rules (Formulae)
Explanation:
• Taxonomy validation rules are applied if the filing indicator is activated
• We have set all EBA taxonomy validation rules as signaling rules
• Banks must comply with all taxonomy validation rules and filing rules
• Banks must resubmit their reports in case of errors
5. Taxonomy validations (2)
12 September 20169
Publication:
• Taxonomy validation rules on the DLR information page (activated/deactivated) during
transitional period
• Once every quarter, on the last business day of the reference period at the latest
Feedback on results:
• In correct/incorrect situations
• Through the DLR portal
• Filing rules: txt
• Taxonomy validation rules: Excel, txt
• On average 0.5 to 1 hour, at 7 a.m. the next business day at the latest
• We expect to receive resubmissions after the ITS date within one business day
• If you disagree with taxonomy validation, please submit a Q&A to the EBA and pass on
the Q&A number to your contact at the Supervisory Statistics Banks department
6. Consistency and plausibility checks - Consistency checks
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Consistency checks include:
• In-report consistency checks
• Cross-report consistency checks
• Checks on filing indicators
Explanation:
• Results are either correct or incorrect
• Banks must comply with all consistency checks
• Banks must resubmit their reports in case of errors
• Consistent with EBA syntax
• Consistent with EBA margins (see annex slides on data precision requirements)
• More information on filing indicators on slide 12
6. Consistency and plausibility checks – In-report and cross-report consistency
checks
12 September 201611
Publication:
• In-report and cross-report consistency checks are published on the DLR portal
information page
• Once every quarter, on the last business day of the reference period at the latest
Feedback on results:
• In correct/incorrect situations
• Through the DLR portal
• In Excel format (see slide 15 on output)
• For in-report consistency checks: in principle the next business day
• For cross-report consistency checks: in principle on the business day following the
receipt of all reports for which these checks have been set
• We expect to receive resubmissions after the ITS date within one business day
• If you disagree with consistency checks, please inform your contact at the
Supervisory Statistics Banks department
6. Consistency and plausibility checks – Checks on filing indicators
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Publication:
• "Required templates and filing indicators" document on the DLR portal information
page
• Updated in case of changes
• Scheduled changes:
o additions for new reports
o incorporation method for filing indicators (see annex slide on Filing indicators)
Feedback on results:
• Only in incorrect situations
• Through the DLR portal
• Excel format
• On ITS date at the latest
• We expect to receive resubmissions after the ITS date within one business day
• Contact your contact at the Supervisory Statistics Banks department in case of
questions
6. Consistency and plausibility checks - Plausibility checks
12 September 201613
Plausibility checks include:
• In-report plausibility checks
• Cross-report plausibility checks
• Outlier analysis
Explanation:
• Plausibility checks may result in findings requiring you to provide an explanation
• Based on your explanation, you may be required to resubmit your report
• Consistent with EBA syntax
• Consistent with EBA margins (see slides on data precision requirements)
6. Consistency and plausibility checks - Plausibility checks
12 September 201614
Publication:
• In-report and cross-report plausibility checks are published on the DLR portal
information page
• Once every quarter, on the last business day of the reference period at the latest
Feedback on results:
• Only in case of findings
• By email
• In Excel format (see slide 15 on output)
• For in-report plausibility checks: in principle the next business day
• For cross-report plausibility checks: in principe on the business day following the
receipt of all reports for which these checks have been set
• We expect to receive resubmissions after the ITS date within one business day
• Note: If the fall-back scenario is applied, we will follow the current procedure for
cross-report consistency and plausibility checks
6. Consistency and plausibility checks - Output
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1. Additional sheet with total number of errors and general information
2. Current sheet with minor adjustments
3. Click through to sheet with entered values
Note: This output format is not used for checks on filing indicators and outlier analysis.
2
3
1
6. Consistency and plausibility checks - Outlier analysis
12 September 201616
Outlier analysis
• Last period relative to preceding period
• Number of reported data points exceeds 25%
• Data deviations exceed 25%
• Disappear and appear (empty -> filled, filled -> empty)
Publication:
• Not applicable
Feedback on results:
• Only in case of findings
• By email
• Excel format
• After ITS date
7. Other quality checks
12 September 201617
Other quality checks include:
• Thematic data quality checks (by DNB, ECB and EBA)
• Financial analyses (as part of regular supervision)
7. Other quality checks - Thematic data quality checks
12 September 201618
Thematic data quality checks
• Data analysis aimed at specific themes/focus areas
• Development of new consistency and plausibility checks
Publication:
• These checks will not be published
• New consistency and plausibility checks will be published on the DLR portal as soon
as they are implemented as regular checks
Feedback on results:
• Only in case of findings
• By email
• Excel format
• Ad hoc
• Response within 3-5 business days (case-by-case decisions) for findings arising
from thematic/focus area data analysis
• Response within 5 business days for new consistency and plausibility checks
7. Other quality checks - Development of new consistency and plausibility checks
12 September 201619
Trigger
• Identified DQ issue (on-site)
• Question of institution (confusion about EBA ITS)
• EBA Q&A
Definition
of checks
• Based on standard notation (consistent with EBA syntax)
• No overlap with taxonomy validation rules or consistency and plausibility checks
Testing
checks
• New consistency/plausibility checks with results to institutions forfeedback
• Receive and process institutions' feedback
• Update of consistency/plausibility checks
DNB
implementation
• Publication of consistency and plausibility checks
• Implementation as part of regular process- Consistency checks see slides 10 and 11 on consistency checks- Plausibility checks see slides 13 and 14 on plausibility checks
EBA
implementation
• Communication regarding consistency and plausibility checks with the ECB/EBA
• Promote implementation in EBA taxonomy (consistency checks)
Any suggestions for
improving the testing
of new checks?
Or preferences for:
• Test periods
(Q1, Q2, Q3, Q4)
• Test timelines
• Test panel
(SIs & largest LSIs)
7. Other quality checks - Financial analysis
12 September 201620
Financial analysis (as part of regular supervision)
• Analysis of non-financial and financial risks
• Analysis also focused on benchmarking (peer group analysis)
Publication:
• Not applicable
Feedback on results:
• Only in case of findings
• By email
• Format: HTML (email) or Excel
• On an ongoing basis
• Response period depending on findings
8. Other matters - Resubmissions
12 September 201621
• Resubmissions for reports from the September 2016 reference
period must be submitted in XBRL
• e-Line will remain available for resubmissions before the
September 2016 reference period during six months
• Reporters have expressed their preference for using e-Line for
these resubmissions
• Please contact us if you wish to use the DLR portal for this
purpose
8. Other matters - Changes to the DLR portal
12 September 201622
• The DLR portal will be amended to allow reporting on organisational units other than reporting institutions as of 1 October
8. Other matters - Testing environment
12 September 201623
• New DPM (DPM 2.5) as of 1 January 2017 starting from the
December 2016 reference period
• After completion of the test reporting for banks, we will no longer
offer a testing environment
• We expect banks to have tested the generation of XBRL reports
and their validation against the applicable EBA taxonomy, filing
rules and validation rules in their own internal environment
before submitting their reports
• EBA taxonomy, filing rules and validation rules are known and
published on the EBA website
8. Other matters - Questions
12 September 201624
• Any questions?
9. Rounding off and follow-up
12 September 201625
Wishes and preferences already known to the CRAP
• Explanatory notes to additional consistency checks
• Include start and end dates in DNB's publications of taxonomy
validations, consistency and plausibility checks
• Receiving feedback at the earliest possible moment
Follow-up actions
• Wishes and input regarding testing new consistency and
plausibility checks can be addressed in the CRAP
• Agree on follow-up approach in the CRAP
Annexes - Data precision requirements (1)
12 September 201626
Source: EBA XBRL filing rules version 4.1, 11 August 2015
Annexes - Data precision requirements (2)
12 September 201627
Source: EBA XBRL filing rules version 4.1, 11 August 2015
Annexes - Data precision requirements (3)
12 September 201628
Source: EBA XBRL filing rules version 4.1, 11 August 2015
Annexes - Filing indicators
12 September 201629
Always requiredAlways not required
Optional
Data reportedF.I included
(with find:filed = TRUE)
F.I included
(with find:filed = TRUE)
F.I included
(with find:filed = TRUE)
Data NOT reported
F.I included
(with find:filed = TRUE)
F.I NOT includedF.I included
with find:filed = FALSE