The full and detailed technical specification for the technology system of a ECB and Eurosystem designated loan level data repository

La demande est réussie.

Dear European Central Bank,

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the following information:

1. The full and detailed technical specification for the technology system of a Eurosystem designated loan level data repository, setting out:
a. all the technical requirements that are applicable to the technology systems of a Eurosystem designated loan level data repository and which are not set out in Annex VIII of Guideline ECB/2-14/60; and
b. all the technical requirements which, if met by the technical systems of an applicant for Eurosystem designated loan level data repository status, will satisfy the technical qualifications of Annex VIII of Guideline ECB/2014/60.

2. The full and detailed set of requirements and benchmarks against which the ECB tests the technical systems of applicants for Eurosystem designated loan level data repository status.

3. A copy of the specification document that sets out the requirement that, in respect of each RMBS loan level data submission, the mandatory fields Pool Cut-off Date (AR1) and Pool Identifier (AR2) should be counted once and not counted for each reported loan in the RMBS template, which requirement was communicated to EuroABS Ltd by letter, dated 31 January 2018.

4. A copy of the specification document that describes any assumptions about the file structure upon which a designated loan level data repository must base its implementation of the following loan level data scoring algorithm, which algorithm is posted on the ECB’s website: “The ABS’s score will reflect (i) the number of mandatory fields reported as “ND,1” relative to the total number of mandatory fields and (ii) the number of mandatory fields reported as “ND,2”, “ND,3” or “ND,4” relative to the total number of mandatory fields” .

5. Please also provide documentation setting out the ECB’s processes for (i) receiving and dealing with questions about any ambiguity or error that may exist or arise in the technical specification for Eurosystem designated loan level data repositories; (ii) clarifying and resolving such ambiguity or error; and (iii) providing an opportunity for applicants for Eurosystem designated loan level data repository status to incorporate changes to reflect such clarification or resolution both before and during the application process. (Please note that EuroABS is already aware of the provision for the ECB to require one or more technical demonstrations during the application process.)

6. Copies of (relevant sections of) all written communications between the ECB and European DataWarehouse GmbH (“EDW”) about data scoring algorithms (the “Algorithms”) and/or the implementation of the same.

7. Copies of (relevant sections of) all written communications between the ECB and EDW that pertain to, suggest or set out any agreement between the ECB and EDW about the technical specification for designated loan level data repositories and/or any element of the same, including (without limiting the generality of the foregoing) about the implementation of the Algorithms and the scoring of individual files.

8. Any and all documentation indicating the process by which the ECB clarified and finalised the technical specification that was ultimately approved by the ECB and implemented by EDW during the period leading up to the ECB’s approval of EDW as a designated loan level data repository.

9. Copies of (relevant sections of) communications between the ECB and EDW about the development of EDW’s technical system for the provision of loan level data repository services, which communications were made prior to the ECB’s approval of EDW as a designated loan level data repository.

10. Copies of (relevant sections of) communications between the ECB and EDW about any revisions or changes to EDW’s technical system for the provision of loan level data repository services, which communications were made subsequent to the ECB’s approval of EDW as a designated loan level data repository.

11. A copy of any documentation indicating the schedule (timetable) or the times and/or dates of meetings conducted between the ECB and EDW in the period leading up to the designation of EDW as a Eurosystem loan level data repository.

12. Copies of the minutes of all meetings between the ECB and EDW during which any technical details of the loan level data repository system requirements have been discussed.

13. Notes of any calls between the ECB and EDW during which any technical details of the loan level data repository system requirements have been discussed.

14. Any recordings (or any transcripts of the same) of all meetings between the ECB and EDW during which any technical details of the loan level data repository system requirements have been discussed.

Yours faithfully,

Nicola Kempton
on behalf of EuroABS Limited

Access to documents,

Dear Ms Kempton,

The ECB confirms receipt on 20 June 2018 of your request for access to ECB documents on the above-mentioned subject. Access to ECB documents is governed by Decision ECB/2004/3 (the unofficial consolidated version of this ECB Decision is available at http://www.ecb.europa.eu/ecb/legal/pdf/0... ). Pursuant to Art. 7.1 of this Decision, your application shall be handled within 20 working days (excluding ECB holidays) from the date of its receipt.

We note that the scope of your application is particularly broad. In line with Article 6.3 “in the event of an application relating to a very long document or to a very large number of documents (e.g. covering a particularly long period of time), the ECB may confer with the applicant informally, with a view to finding a fair solution”.

In order to allow the ECB to assess your request within the time limits foreseen in Decision ECB/2004/3, the ECB will break down your request into smaller batches. We would therefore be grateful if you could identify the parts which should be dealt with as a priority.

Following receipt of your specification, the ECB will proceed with the assessment of the first part of your request and confirm the timeline for the ECB reply.

Yours sincerely,

Compliance and Governance Office
DG Secretariat
European Central Bank
Sonnemannstrasse 20
60314 Frankfurt am Main
[email address]
[email address]

Afficher les sections citées

Dear European Central Bank,

Thank you for your 21 June response.

Logically, our request could be divided into two sections. 1-5 and 6-14. Both sets of requests are closely related and equally important. Please do your best to meet all the request sections equally.

We would be happy to confer with you formally of informally about our request, although we do need access to the requested documentation and consider this important and in the public interest.

Yours sincerely,

Nicola Kempton

Access to documents,

2 Attachments

Dear Ms Kempton,

Please find enclosed the ECB's reply to your request of 20 June 2018 for access to ECB documents on the above-mentioned subject relating to points 1 to 6. Please note that we will now proceed with the assessment of the remaining points of your request as provided for in Decision ECB/2004/3, with a new time line for reply of 20 working days starting from 18 July 2018.

Yours sincerely,

Compliance and Governance Office
DG Secretariat
European Central Bank
Sonnemannstrasse 20
60314 Frankfurt am Main
[email address]
[email address]
____________________________________________________________

Afficher les sections citées

Dear Access to documents,

Many thanks for your first set of responses (the “Part 1 Response”) to EuroABS’ request (the “EuroABS Request”).

The Part 1 Response directs EuroABS to Annex VIII of Guideline EU 2015/510 of the ECB on Loan-Level Data Reporting Requirements for Asset-Backed Securities and the Procedure for the Eurosystem’s Designation of Loan-Level Data Repositories, the ECB ABS loan-level data templates and the reporting instructions to data providers specified in the ECB taxonomy (the “Publicly Available Documents”).

EuroABS is aware of the existence and content of the Publicly Available Documents. EuroABS is also aware that the level of technical detail set out in the Publicly Available Documents is not, in and of itself, sufficient to support the creation of a technical system that is capable of satisfying the ECB’s requirements for ECB-designated loan level data repositories. Indeed, the ECB has, in correspondence, provided to EuroABS certain crucial technical requirements that are (or were) not set out in the Publicly Available Documents. We acknowledge that the Publicly Available Documents were amended in February this year to incorporate some of those requirements.

The Part 1 Response generally (and the statement: “We regret to inform you that no documents have been identified for point[s] 1 [and 6] of your request” in particular) suggests that the ECB does not possess or control the full, detailed technical specification for the technology system of a Eurosystem-designated loan level data repository, whether set out in a single document or in a set of documents. Please confirm that: (1) this is indeed the case; and (2) the ECB has or controls no documentation that sets out any technical requirements for Eurosystem-designated loan level data repositories other than the Publicly Available Documents and copies of its communications with EuroABS. If neither confirmation can be given, please provide the appropriate document or set of documents.

We note that the Part 1 Response mainly deals with EuroABS’ requests for documents that set out the ECB’s technical requirements and states that the ECB will respond separately to EuroABS’ remaining requests. Point 6 of the EuroABS Request asks for copies of certain communications rather than for technical specification documentation. As such, it would appear to sit more comfortably with points 7-14 of the EuroABS Request, rather than with points 1-5 and we therefore query whether the Part 1 Response referred to point 6 in error. Please confirm whether the reference to “point 6” in the Part 1 Response is correct or whether the ECB will respond to that point 6 in its response to the remaining points in the EuroABS Request.

Yours sincerely,

Nicola Kempton

Access to documents,

Dear Mr Kempton,

Thank you for your email.

We can confirm your understanding that (a) the ECB identified no documents for points 1 and 6 of your application and that (b) point 6 was indeed assessed under the first part of your application.

Issues related to how technical requirements for Eurosystem-designated loan level data repositories are set out, relate to points 7 and 10 of your application, which are currently being assessed by the ECB.

Please rest assured that we are doing our best to respond to the remaining points of your application in a timely manner.

Yours sincerely,

Compliance and Governance Office
DG Secretariat
European Central Bank
Sonnemannstrasse 20
60314 Frankfurt am Main
[email address]
[email address]

Afficher les sections citées

Access to documents,

Dear Ms Kempton,

Much to our regret and due to the need to consult third parties, we were not be able to provide you with the ECB’s reply to the second part of your request within the foreseen deadline. We therefore have to invoke Article 7.3 of Decision ECB/2004/3 https://www.ecb.europa.eu/ecb/legal/pdf/... and extend the time limit provided to reply by an additional 20 working days, starting from 20 August 2018.

Please accept our apologies for this delay and please rest assured that we will do our best to respond to you within the new deadline.

Yours sincerely,

Compliance and Governance Office
DG Secretariat
European Central Bank
Sonnemannstrasse 20
60314 Frankfurt am Main
[email address]
[email address]

Afficher les sections citées

Access to documents,

5 Attachments

Dear Ms Kempton,

Please find enclosed the ECB's reply to the second part of your request dated 20 June and further specified on 25 June 2018 for access to ECB documents on the above-mentioned subject.

The transmission contains 12 pdf files in total: the reply letter; the annex (copy of your request); 8 documents falling under item 7 and 2 documents falling under item 10.

Yours sincerely,

Compliance and Governance Office
DG Secretariat
European Central Bank
Sonnemannstrasse 20
60314 Frankfurt am Main
[email address]
[email address]

Afficher les sections citées

Dear ECB

Thank you very much for your response

Yours sincerely

Nicola Kempton