Bundesbank published a circular to inform about the procedure of removal of duplicates in the AnaCredit reports submitted to Bundesbank. Bundesbank had requested the institutions that had sent duplicates in the course of their AnaCredit report, by means of individual letters, to correct such incorrectly delivered data records by June 30, 2021. However, as many institutions are busy preparing for the new supervisory reports in accordance with CRR2 Bundesbank is extending the deadline for corrections to October 31, 2021 and will not activate the validation rule, which ensures that an identifier cannot belong to two different contractual partner data records (UID rule), until November 2021. Should individual banks not be able to meet the deadline, Bundesbank expects institutions to notify the signatories of this letter by September 30, 2021 so that an individual action plan can be drawn up.
A change in the contractual partner ID, which is the most common reason for the duplicates, was not intended at any point in the AnaCredit report and is, therefore, to be interpreted as a violation of the reporting obligation from the start. These reported duplicates not only represent a violation of the reporting requirements of the Bundesbank and ECB Regulation published in the guidelines, but they also cause considerable problems in the system of Bundesbank and prevent the credit data records in question from being transmitted to ECB. Against this background, Bundesbank had announced the introduction of the UID validation rule for 08/2020 by Bundesbank in February 2020 and published it in the validation manual (version 10). This rule checks the reporting requirement that has existed since the beginning of the AnaCredit report, a requirement which stipulates that a submitted national identifier must be unique and, therefore, only be reported for a single contractual partner identifier. If this is not the case, the submitted contractual partner master data records will be rejected.
Related Link (in German): Circular (PDF)
Keywords: Europe, Germany, Banking, AnaCredit, Reporting, Validation Rules, Unique Identifier, UID, Bundesbank
Scott is a Director in the Regulatory and Accounting Solutions team responsible for providing accounting expertise across solutions, products, and services offered by Moody’s Analytics in the US. He has over 15 years of experience leading auditing, consulting and accounting policy initiatives for financial institutions.
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