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报告摘要

CECA Response to CEBS Consultation Paper (CP14) on Large Exposures Regime

Core Content

The Spanish Confederation of Savings Banks (CECA) has responded to the CEBS Consultation Paper (CP14) regarding the first part of the European Commission's advice on revising the large exposures regime. CECA represents 46 independent retail banks in Spain, which are private foundations and operate nationwide without territorial restrictions. Collectively, these banks account for over 50% of the national market share.

Key Information

CECA's Role: CECA serves as a representative body for Savings Banks in Spain, engaging with public authorities and the international financial community. It acts as a study center, collaborates with financial regulators, and coordinates operational activities related to information, communication, and marketing.
Appreciation for Engagement: CECA appreciates the opportunity to contribute its views on the CP14 and the broader revision of the large exposures regime.
Positive Assessment of CP14: CECA views the CP14 as a positive step in redefining the large exposures regime, though it emphasizes that its final evaluation will depend on the forthcoming advice on the second part of the Commission's Call for Advice.
Regime Design and Purpose: CECA agrees that a large exposures regime should act as a backstop against unforeseen risk events. They note that most Savings Banks already rely on the regulatory regime for internal measurement and management of large exposures.
Regulatory Limits: CECA supports the current 25% regulatory limit for large exposures, as it aligns with their internal practices. However, they consider the 800% threshold irrelevant and not aligned with the intended purpose of the regime.
Pillar 2 and Concentration Risk: CECA highlights that Pillar 2 requirements provide clear incentives for institutions to improve their management of concentration risk. They do not foresee any potential conflicts or overlaps between Pillar 2 and the regulatory limits for large exposures.
Simplicity of Design: CECA emphasizes the importance of maintaining a simple design for the regime. They argue that complicating the framework would increase costs and reduce its effectiveness, especially since many unforeseen risk events would already be addressed under Pillar 1.
Convergence Across Member States: While CECA supports the idea of consistent application of the regime across all 27 EU Member States, they acknowledge the challenges in achieving convergence. They welcome initiatives that aim to harmonize the regime, including specific exemptions for exposures.
Timing of Revisions: CECA suggests that any amendments to the current framework should be introduced only after the new regulation is fully adopted and implemented by institutions. They note that many institutions are still adapting to Basel II requirements and that premature changes could create unnecessary burdens.

Main Views

Support for the Regime: CECA supports the general concept of a large exposures regime as a backstop for unforeseen risk events.
Preference for Simplicity: A simple and straightforward design is seen as essential to reduce implementation costs and enhance clarity.
Relevance of Limits: The 25% limit is considered relevant and practical, whereas the 800% threshold is deemed unnecessary.
Pillar 2 as a Complement: Pillar 2 requirements are viewed as a more appropriate mechanism for addressing concentration risk, rather than the regulatory limits.
Need for Convergence: CECA advocates for convergence of the regime across EU Member States, recognizing the challenges but supporting the initiative.
Timing Considerations: CECA recommends delaying any revisions until the new regulation is fully integrated and understood by institutions, especially in jurisdictions where the CRD is still being transposed.