Background overview
In December 2023, the State Administration of Financial Supervision and Administration issued the Notice on Filling in the Off-site Regulatory Statements of the Banking Industry in 2024 (hereinafter referred to as the "System Notice"). The off-site regulatory report is an important starting point for regulators to monitor the risk status of banks, and the content of the system fully reflects the requirements of recent regulatory regulations and adapts to the development and changes of the financial industry. On the basis of a series of measures such as the Measures for the Risk Classification of Financial Assets of Commercial Banks (hereinafter referred to as the "Risk Classification Measures"), the Measures for the Capital Management of Commercial Banks (hereinafter referred to as the "New Capital Regulations") and the Measures for the Country-specific Risk Management of Banking Financial Institutions (hereinafter referred to as the "Country-specific Risk Management Measures") issued this year, the "System Notice" requires financial institutions to attach great importance to the statistical work of the new capital regulations, asset quality, real estate, inclusive finance and other items, which shows that refined risk management has become imperative.
The "System Notice" not only clarifies the adjustment of the content of the report, but also puts forward the specific requirements for the internal process system of off-site supervision report statistics, information system construction, data quality control, and report quality. In this regard, Yuejin Digital Technology (Shanghai) Co., Ltd. sorted out and summarized the relevant changes in the content of the report and the corresponding precautions for submission according to the content of the notice and related attachments.
Report content adjustments
A total of 132 statements were involved in this system upgrade, including 86 new statements (75 were capital adequacy ratio statements), 41 were modified statements, and 5 were suspended statements.
一、Add a new report
（一）Statements related to the new capital regulations
As a major policy this year, the "New Capital Regulations" has increased the transition of the old and new parallel reporting periods due to the difficulty of filling in the report, so it has brought 75 new statements to the 1104 report in 2024 as soon as it is released. In terms of the total amount, it has indeed increased a lot, but in fact, due to the setting of different gears and different measurement methods to match different scales, the number of statements submitted by banks is not so "terrifying".
Regarding the classification requirements of commercial banks (as shown in the figure below), the classification is based on the business scale and risk differences of commercial banks at the end of 2023.
Next, the bank can submit the corresponding capital-related statements according to its own level. In addition to the statements of banks that have been approved to use the advanced method of capital measurement, we have counted the statements and working papers that need to be submitted in the first, second and third tiers respectively (as shown in the figure below): there are a total of 39 institutional statements in the first tier, including 12 submitted statements and 27 working papers; The total number of second-tier banks was slightly smaller (mainly reflected in the measurement of market risk), including 11 submitted statements and 23 working papers; The third-tier banks have the least, with only 7 tickets submitted.
In addition, although the 1104 system upgrade does not mention the relevant requirements for information disclosure in the New Capital Regulations, this part will also need to be submitted in 2024 as a key revision of the New Capital Regulations. We have also sorted out the content of information disclosure submissions according to each file. The details are as follows:
From the perspective of the number of statements, it is more friendly to second- and third-tier banks. For market risk-related statements, the second-tier banks meet the conditions of the simplified standard method to measure market risk capital by this method, and the measurement method and the size of the bank are more reasonable. Third-tier banks do not need to measure market risk capital, so they are exempt from filling in market risk-related statements, so on the whole, the 1104 upgrade is generally friendly to second-tier banks, and it can even be said to be a significant "burden reduction" for third-tier banks, which also reflects the requirements of the regulatory implementation of the differentiated capital supervision system of the "New Capital Regulations". (The detailed submission list is shown below)
*Blue represents the submission report
（二）Support development and branch reports
1."S66 Three Major Project Credit Statistics"
S66 in 2023 is the "Affordable Housing Project Loan Sub-regional Situation Table", in 2024 the original table will be deleted synchronously, with the "three major project credit statistics table" to follow the table number, the main statistical reporting institutions to carry out the "level-emergency dual-use" public infrastructure construction, urban village renovation and affordable housing related loan business, in fact, to expand the statistical caliber, is the central "three major projects" policy guidance on the regulatory report of the landing.
2.《SF70 Science and Technology Finance Fact Sheet》
The new SF70 in the institutional category, the first part of the S70 statement of the benchmark legal person, mainly reflects the regulator's attention to the financing of the technology finance industry.
（三）Institutional reports
Nine new institutional statements were added, mainly focusing on urban commercial banks, financial asset management companies, financial leasing companies, enterprise group finance companies, policy banks and wealth management companies
二、Modify the report
The scope of the 1104 system upgrade is larger than last year, with a total of 16 legal entity statements, and the branch reports have also been adjusted and upgraded accordingly. The specific changes are as follows:
（一）Changes in the focus of the legal entity's statements
*For more information on the interpretation of the content of the "Country Risk Management Measures", our company has also sorted out the relevant key points, and will release the relevant official account in the future, so stay tuned!
（二）Other changes in the statements of legal entities
The revision also adds statistics on the indicators of deposits, cash management wealth management products, science and technology finance, inclusive finance, and pension finance absorbed by the Internet, which reflect the country's growing attention to such businesses from policy guidance to statement indicators. At the same time, it also puts forward higher requirements for the management and control of credit risk, liquidity risk, foreign exchange risk, etc., and urges banks to improve the quality of collection of underlying data.
（三）Institutional reports
三、Stop reporting reports
A total of 5 reports were suspended in this upgrade, including 1 S66 statement of legal entities, which was replaced by the "Statistical Table of Credit Situation of the Three Major Projects" after deletion, and 1 corresponding branch statement and 3 institutional statements.
四、Fourth, the filling instructions and other adjustments
The focus of this adjustment is the change in the reference basis of the five-level classification of loans, which has little impact on the filling of downstream personnel, but puts forward higher requirements for upstream business personnel to evaluate the quality of loans. However, due to the early release of the "Risk Classification Measures", many banks are estimated to have adjusted the classification criteria for the five-level classification in accordance with the latest issuance in the middle of the year, and now it is also implemented on the 1104 report.
五、Submission schedule
Due to the large number of new and revised tables this year, in order to ensure the consistency of the regulatory report data, it is not only necessary to switch to the new template for submission, but also need to use the new form to supplement the data at the end of 2023. To this end, we have compiled the following submission schedule according to the caliber and frequency of submission for reference.
1.New capital-related statements (new rules)
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Historical data supplementation time:
2.Non-capital related statements
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The frequency of this revision only involves 2 reports (marked in red in the figure below), and the rest are new reports (the scope is referred to "I. New Reports" in this article) with a clear frequency.
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Historical data supplementation time:
Submit TIPS for quality improvement
（一）Strengthen the capacity building of regulatory reporting
Establish mechanisms and processes for legal representatives or principal responsible persons to bear ultimate responsibility for the quality of regulatory data, continuously improve the working mechanism for regulatory statistics, improve the level of digitization of regulatory statistics, strengthen the awareness of responsibility of reporting personnel, and ensure that the number of personnel, professional ability, accountability, and incentive mechanisms all meet the needs of regulatory statistics.
（二）Promptly revise the regulatory statistics system of the institution
Combined with the issuance of off-site supervision documents, the statistical business system and data aggregation process of the issuing bank should be revised in a timely and accurate manner, and the standards for the number of new and revised statements should be standardized. At the same time, statistical training is organized to ensure that statisticians and business personnel of various departments and branches accurately understand the new reporting requirements.
（三）Continuously optimize and upgrade the information system
The regulatory reporting support system should be continuously optimized and upgraded, and in the process of transforming the basic business system and developing new business systems, the connection with the regulatory statistical reporting support system should be strengthened to ensure that the automation of regulatory statistical reports and the construction of business systems are carried out simultaneously. At the same time, it strengthens the automatic identification and early warning capabilities of abnormal change data and erroneous data, and improves the quality and efficiency of regulatory reporting.
（四）Continue to improve data quality control mechanisms
A data quality monitoring system for the whole life cycle should be established, data source management should be strengthened, and business information should be entered into the information system in a timely, comprehensive and accurate manner. Strengthen data management requirements, improve data quality control mechanisms, continuously monitor and report data misstatements, regularly organize on-site data quality inspections, implement accountability and rectification mechanisms for major and recurrent data errors and omissions, and assign responsibility to specific departments and individuals.
（五）Optimize the off-site regulatory information reporting mechanism
It is necessary to do a good job in reporting regulatory information on a monthly and quarterly basis, track and study the change trend of the main regulatory indicators, analyze the changes in relevant data and the reasons, strengthen the analysis of abnormal change indicators, and effectively improve the quality of off-site regulatory information reporting.
Contact Us
RIKING Digital Technology (Shanghai) Co., Ltd. is a well-known financial supervision and compliance software solution provider in the financial industry. Founded in August 2013, it has been deeply engaged in the field of regulatory technology for more than 10 years, providing one-stop regulatory compliance consulting and software solutions covering the whole process of regulatory data governance, data mart, risk and compliance management, credit investigation, anti-money laundering and liquidity risk control for the world's leading financial institutions.Tel:400 921 0806.
