Similarly, in some jurisdictions may be constraints on the usage for supervisory purposes of data obtained from sources other than the CR, especially if such data is to be used for taking specific supervisory actions and/or making other specific policy decisions. Indeed, some central banks and other financial supervisors are bounded by legislation or regulations and can only take specific supervisory actions and decisions based on the information available at the CR or at other credit databases they themselves operate. When it comes to cross-border lending activities, micro-prudential supervisors may not be able to obtain and use credit data available in foreign CRs or other CRSPs. This is often the case when a Memorandum of Understanding (MOU) or other mechanism to facilitate cross-border data exchanges has not been agreed between central banks or between other supervisory authorities, and/or between private sector operators of CBs and CCRCs. At present, a number of relevant private and public sector initiatives are underway to address the difficulties in cross-border data exchanges. At the operational level, to be able to use the data effectively it is highly important that the CR have the functionalities that supervisors require, together with a robust technological infrastructure supporting it. For example, even if the CR has comprehensive and high quality data, supervisors may be unable to exploit such data fully if the CR system itself has limited reporting tools and/or is not supported with adequate data warehousing tools. In cases like this, regular reports tend to be not comprehensive enough and the CR lacks flexibility to make adjustments to such reports. Likewise, it may be difficult for the CR to produce robust ad-hoc reports in a timely manner. These operational problems tend to be amplified as the size of the database increases. These operational problems are not exclusive to CRs. CBs and/or CCRCs may also have limited functionalities with regard to reporting data back to users in this specific case – the supervisors - regardless of the amount and quality of the data available in them.
Similarly, in some jurisdictions may be constraints on the usage for supervisory purposes of data obtained from sources other than the CR, especially if such data is to be used for taking specific supervisory actions and/or making other specific policy decisions. Indeed, some central banks and other financial supervisors are bounded by legislation or regulations and can only take specific supervisory actions and decisions based on the information available at the CR or at other credit databases they themselves operate. When it comes to cross-border lending activities, micro-prudential supervisors may not be able to obtain and use credit data available in foreign CRs or other CRSPs. This is often the case when a Memorandum of Understanding (MOU) or other mechanism to facilitate cross-border data exchanges has not been agreed between central banks or between other supervisory authorities, and/or between private sector operators of CBs and CCRCs. At present, a number of relevant private and public sector initiatives are underway to address the difficulties in cross-border data exchanges. At the operational level, to be able to use the data effectively it is highly important that the CR have the functionalities that supervisors require, together with a robust technological infrastructure supporting it. For example, even if the CR has comprehensive and high quality data, supervisors may be unable to exploit such data fully if the CR system itself has limited reporting tools and/or is not supported with adequate data warehousing tools. In cases like this, regular reports tend to be not comprehensive enough and the CR lacks flexibility to make adjustments to such reports. Likewise, it may be difficult for the CR to produce robust ad-hoc reports in a timely manner. These operational problems tend to be amplified as the size of the database increases. These operational problems are not exclusive to CRs. CBs and/or CCRCs may also have limited functionalities with regard to reporting data back to users – in this specific case the supervisors - regardless of the amount and quality of the data available in them.
credit_reporting_in_financial_regulation_and_supervision-for_public_consultation.docx