EBA欧洲银行-20141215-EBA-CP-2014-25_3页_289kb

EBA Banking Stakeholder Group Summary on EBA/CP/2014/25

Core Content

The EBA Banking Stakeholder Group (BSG) has provided general comments and detailed replies to questions regarding the EBA/CP/2014/25 Consultation Paper, which outlines draft guidelines on the application of simplified obligations under Article 4 of the Bank Recovery and Resolution Directive (BRRD). The BSG emphasizes the importance of harmonizing supervisory rules and practices across the European Union to ensure fair competition and efficiency in cross-border groups. They also highlight the benefits of facilitating data sharing between European supervisors and avoiding reporting duplications for banks.

Main Views

General Comments

• The BSG supports the implementation of proportionality in the context of recovery and resolution planning.
• They believe that simplified obligations should be applied to institutions that do not pose a systemic risk, thereby reducing unnecessary regulatory burdens.
• The BSG welcomes the use of existing supervisory processes, such as the SREP (Supervisory Review and Evaluation Process), for assessing the applicability of simplified obligations.
• However, they point out that the guidelines apply only to stand-alone institutions, not to those included in a group recovery and resolution plan. For such institutions, the level of detail and frequency of updates are determined by the group plan requirements, even if they are of low systemic importance.

Replies to Questions

1. Mandatory and Optional Indicators:
   The BSG agrees that the list of indicators provided in the guidelines is adequate and sufficient to determine the application of simplified obligations.
   They note that the mandatory indicators should not impose an excessive burden on smaller institutions.

2. Level of Detail:
   The BSG considers the level of detail in the guidelines appropriate, as it provides a balanced framework that is neither too rigid nor too flexible.

3. Business Models and Investment Firms:
   The BSG believes the lists of indicators are sufficient to cover the full range of business models and investment firms.
   However, they stress that a qualitative assessment by competent authorities and resolution authorities should supplement the use of these indicators when making decisions on simplified obligations.

Key Information

• Objective: The consultation paper aims to define the criteria for applying simplified obligations under the BRRD.
• Proportionality Principle: Central to the BSG's comments, it ensures that regulatory requirements are commensurate with the risk profile of institutions.
• Applicability: Simplified obligations are only applicable to stand-alone institutions, not to those within group recovery and resolution plans.
• Data Sharing: The BSG supports the enhancement of data sharing between European supervisors to improve efficiency and reduce duplication.
• Supervisory Process: The SREP process is recognized as a valuable tool for assessing the risk profile of institutions, which can inform the application of simplified obligations.

Conclusion

The EBA Banking Stakeholder Group endorses the principle of proportionality and the harmonization of supervisory practices. They believe the draft guidelines provide a reasonable and balanced framework, though they emphasize the need for qualitative assessments and the importance of group recovery and resolution plans in determining the level of detail required for institutions involved in such plans. The BSG also highlights the benefits of data sharing and reducing reporting burdens for banks that do not pose systemic risks.