I have to build an operational risk model and to be compliant with Basell II and III regulations I thought of using AMA (Advanced measurement approach) or COM (change of measurement). We have no historical data in the sense that what my company does is spreading around a questionnaire where the heads of the departments have to indicate for each risk category the amount of money (in their opinion) was wasted for that category and how many times that loss occurred in 1 year. They fill out a table in which there is MIN, MAX, MEDIAN..in Euros.
The goal is to estimate the total losses so I want in the end a number in Euros, and in addition also the distribution of this loss.
Do you agree with using the approaches AMA or COM? I noticed they want in input recordings of the past losses per each category but I do not have such data.
Have you got any reference where it is shown the code to implement those?
Many thanks everybody in advance