Bank of Baroda Submission

Consolidated list of consultation questions
Q1: How far would this particular change go towards addressing any concerns about the need to disclose non-material CoR breaches? We welcome the improvements suggested Q2: Will reporting instances where your bank is “likely to breach” a requirement present particular challenges? Is there a form of words you would prefer for this obligation? It is usually a breach is detected after its occurrence. As regards a breach likely to happen - we are not able to comprehend at this stage. As to the periodicity ,we feel that publishing of breaches should be limited to the period of reporting (same as in DS) ie for a period of one year. If the investor wants to see the previous breaches ,he can always access the previous DS in the website. Therefore, publishing breaches for 5 years can be modified to 1 year. Q3: Do you have any comments on the content of the proposed new webpage and the process for updating it? No additional comments Q4: Please could you provide estimates of the costs to your bank, compared to the current arrangements, arising from:
 any additional process costs you would incur per breach, in the case of breaches that you think you would have discussed with the Reserve Bank under current arrangements; Unable to make any cost estimation  additional cases (if any) of potential or likely future breaches you would expect to report to the Reserve Bank in future, that you would not report at present. None that we could think of Q5: Do you agree that the proposed requirement to give a view on materiality to the Reserve Bank would impose significantly less burden on directors than the current need to handle publication of all non-material breaches? yes, However, materiality threshold needs to be defined ,or else it would become subjective. For example there are threshold levels for tolerance prescribed in the Dashboard. We could have something similar Q6: Do you have suggestions for additions or amendments to this list? No Q7: Do you agree with the proposed timing for inclusion in the DS? Do you have any other comments on the revised wording?

No
Q8: Do you think this is a workable amendment to the director attestation? Yes Q9: What are your views on the balance of benefits and costs of introducing a materiality threshold? already responded above Q10: Do you think this would be a helpful proposal to develop further in due course? Do you agree that it should be given lower priority than the other proposals in this paper? yes, we agree with your views on higher priority Q11: Do you think your bank will need additional preparation time between the finalisation of the reporting notice and its start date, and if so, how long? We may not need additional time Q12: Which of options (a) or (b) do you prefer, and why? b. We could avoid the retro-active assessment, and for reasons of more clarity