EBA欧洲银行-Letter-to-O-Guersent2C20re-Request-for-revised-deadlines-in-the-CRR-for-the-delivery-of-draft-technical-standards_3页_257kb

Summary of EBA's Request for Revised Deadlines in CRR/CRD

Core Content

The European Banking Authority (EBA) has formally requested revised deadlines for the delivery of several draft technical standards under the Capital Requirements Regulation (CRR) and Capital Requirements Directive (CRD). This request is made due to the significant workload and resource constraints faced by the EBA in completing these tasks within the original time frame.

Main Points

• Request for Revised Deadlines: The EBA is seeking new time limits for the submission of certain technical standards, as they have not been delivered by the end of December 2016.
• Reasons for Delay: The delays are attributed to the complexity of the tasks, the need for harmonization across EU member states, and the impact of international developments such as the Basel III revisions.

Key Mandates and Delays

1. Authorisation of Credit Institutions (RTS and ITS)

• Original Deadline: End of December 2016
• Current Expectation: Completion during 2017, most likely around mid-2017
• Reason for Delay: The task involves balancing the need for harmonization with the flexibility of national authorisation processes, especially regarding new entrants and Fintech companies.

2. Consolidation Methods (RTS, Article 382(5) CRR)

• Original Deadline: End of December 2016
• Current Expectation: End of 2017
• Reason for Delay: Interaction with BCBS developments and the Commission's CRR revisions, which have altered the legal basis for consolidation.

3. Exclusion of Transactions with Non-Financial Counterparties in Third Countries (RTS, Article 382(5) CRR)

• Original Deadline: End of December 2016
• Current Expectation: Q1 2017
• Reason for Delay: Lower priority due to re-prioritization based on the Call for Advice on CRR revisions for market risk and counterparty credit risk.

4. Disclosure of Encumbered and Unencumbered Assets (RTS, Article 443 CRR)

• Original Deadline: End of December 2016
• Current Expectation: Q1 2017
• Reason for Delay: Same as above, due to re-prioritization.

5. Remaining CRM Mandates

• Mandates: RTS on immaterial portfolios for IRB approach, RTS on conditional guarantees, RTS on eligible collateral
• Status: Put on hold until the final CRM report is delivered by end of 2017
• Reason for Delay: The EBA is conducting a broad review of the CRM framework as part of its General Regulatory Review of Internal Models, which is expected to provide a more comprehensive regulatory basis.

6. Operational Risk Mandates

• Mandates: RTS on combined use of different approaches, RTS on relevant indicator under accounting standards different from Dir 86/636, ITS on principles for business line mapping
• Status: Put on hold until more clarity on the future framework exists
• Reason for Delay: International developments, such as the removal of the Advanced Measurement Approach (AMA), suggest that these mandates may no longer be optimal in the current regulatory context.

Additional Notes

• The EBA is committed to completing its tasks within the revised deadlines.
• The quality and transparency of the single rule book are of utmost importance.
• The EBA is prepared to discuss the optimal path forward, especially in the context of the CRM report and future Basel Accord revisions.

Conclusion

The EBA is requesting extended deadlines for several technical standards due to the complexity of the tasks and the impact of international regulatory changes. The authority is focused on ensuring the quality and coherence of the regulatory framework, even if it means delaying certain mandates until a more stable and comprehensive regulatory environment is established.