Hello,
Due to the timelag in the data, FIs that are setting targets in 2022, may be using 2020 or 2021 as their base year. What is the proposed approach to address any material movements in a portfolio in 2022?
For example, a base year of 2021 is being used but in early 2022, some material counterparties left the portfolio. Should the FI remove these counterparties from the 2021 baseline for the purposes of setting the target?
Conversely, a base year of 2021 is being used but in early 2022, some material counterparties joined the portfolio. Should the FI add these counterparties on a like for like basis into the 2021 baseline?
To be clear, I am only suggesting this at the point of setting the target as the base year is in the past and may not be reflective of current state.
Many thanks,
Ana