Circular BCL 2017/240 of 21 April 2017 — Introduction of Granular Credit and Credit Risk Data Collection

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Luxembourg, 21 April 2017
To all credit institutions
CIRCULAR BCL 2017/240
Introduction of Granular Credit and Credit Risk Data Collection

Madam, Sir,

This circular aims to inform reporting agents of their reporting obligations under Regulation ECB/2016/13 of 18 May 2016 on the collection of granular data on credit and credit risk (AnaCredit), in accordance with Article 13, paragraph 3 of that Regulation.

Since the data collected under the credit and credit risk data collection are used for various purposes, including financial stability, the Banque Centrale du Luxembourg (BCL) wishes to ensure the most complete coverage possible.

Thus, the BCL will not grant any derogation within the meaning of Article 6 of the aforementioned Regulation and wishes to obtain the information required by Regulation ECB/2016/13 for all banks established in Luxembourg, regardless of their legal status. Furthermore, for entities under Luxembourg law, the legal entity established in Luxembourg must report, in addition to data relating to the head office, also that of each branch established abroad.

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However, in order to avoid double reporting situations, the collection modalities for branches established in a declaring Member State as defined by Regulation ECB/2016/13 will be determined based on agreements currently being negotiated with the various national central banks (NCBs) participating in the AnaCredit collection. Indeed, as provided for in Article 6 of Regulation ECB/2016/13, NCBs must consult each other to avoid double reporting.

Thus, the BCL has decided that:

1. Legal entities established in Luxembourg must submit all data required by Regulation ECB/2016/13 for the legal entity, as well as for each of their branches established abroad. Foreign branches established in another declaring Member State will be excluded if, and only if, this information is collected by another NCB.

2. Branches of foreign banks established on Luxembourg territory must submit all data required by Regulation ECB/2016/13, unless this information is collected by another NCB.

Since the coordination exercise with other NCBs is ongoing, the BCL will shortly contact the affected credit institutions individually to inform them of their reporting obligations.

In this same context, and in accordance with the provisions of Article 16 of the aforementioned Regulation, the BCL does not plan to grant any derogations to "small" reporting agents regarding their reporting obligation and the frequency thereof.

Regarding Recital 15 of the aforementioned Regulation, the BCL informs reporting agents that it will not extend credit data declarations beyond the mandatory scope provided for by that Regulation. Thus, the attributes of Table 1 of Annex II and Tables 2 and 3 of Annex III marked with "N" must not be reported to the BCL. However, in accordance with a specific request from the ECB, the following attributes must be provided even if they are marked "N" in columns 1 to 11 of Tables 2 and 3 of Annex III of Regulation ECB/2016/13:

• Legal Entity Identifier (LEI)
• National Identifier

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In this context, it should be indicated that the BCL has chosen to retain the Commercial and Companies Register (RCS) number as the national identifier for resident counterparties.

Regarding Article 11 "Information Loops for Reporting Agents", the BCL informs reporting agents that it does not currently intend to implement an information loop.

Finally, reporting agents are invited to consult the specific "AnaCredit" section on the BCL website, which provides them with documents related to this new collection. This section will soon be updated with additional instructions regarding both reporting and the format for data transmission.

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All documents available on the BCL website can therefore be downloaded from the link:
http://www.bcl.lu/fr/reporting_reglementaire/Etablissements_credit/AnaCredit/index.html

For any information regarding the application of this circular, please contact the Banking and Monetary Statistics Section directly (email: reporting.AnaCredit@bcl.lu).

Please accept, Madams, Sirs, the assurance of our perfect consideration.

BANQUE CENTRALE DU LUXEMBOURG
The Management
Roland Weyland Pierre Beck Gaston Reinesch
General Director