EBA欧洲银行-ND_EBICletter_2页_159kb

European Banking Industry Committee Summary

Core Content

The document outlines the position of the European Banking Industry Committee (EBIC) on the reduction of national options within the Capital Requirements Directive (CRD). It highlights the importance of aligning national supervisory practices with the objectives of a single European banking market, as well as the need for consistency in reporting and market disclosures under Pillar 3 of the Basel Accord.

Main Points

• Committee Members:
  The EBIC comprises several key European banking associations, including:

  • European Banking Federation (EBF)
  • European Savings Banks Group (ESBG)
  • European Association of Cooperative Banks (EACB)
  • European Mortgage Federation (EMF)
  • European Federation of Building Societies (EFBS)
  • European Association of Public Banks (EAPB)
  • European Federation of Finance House Associations (Eurofinas)
  • European Federation of Leasing Company Associations (Leaseurope)

• Chairperson:
  Mrs. Danièle Nouy, Chairman of the Committee of European Banking Supervisors (CEBS), is the primary recipient of the letter.

• Support for CEBS and the European Commission:
  The EBIC acknowledges the efforts of CEBS and the European Commission to reduce national options in the CRD and agrees that the high number of such options is inconsistent with the goal of a single market.

• Common Industry Viewpoint:
  The EBIC aims to provide a unified industry perspective to assist supervisory authorities in reaching agreement on the approach to national options. They have identified numerous provisions where there is clear consensus on the most suitable solution.

• Non-Prioritization of Options:
  The EBIC clarifies that their lack of comment on the full list of national options does not imply any prioritization or ranking. They emphasize that many options are of high importance, even if specific preferences vary.

• Categorization and Recommendations:
  While the EBIC generally supports the categories used by CEBS to classify recommendations, they have opted for descriptive statements in some cases where the categories were misleading. They also elaborate on the concept of mutual recognition, noting that it can be based on either a single supervisor's decision or a joint decision process between supervisors.

• Practical Interpretation of Rules:
  The EBIC notes that many supervisory divergences stem from the practical interpretation and application of the written rules, rather than from the legislative text itself. They recommend that CEBS continues to monitor these divergences and promote common supervisory practices.

Key Information

• The EBIC seeks to support CEBS and the European Commission in harmonizing national supervisory practices.
• They emphasize the importance of reducing inconsistencies in reporting and market disclosures.
• The document includes a detailed list of national CRD options that have been identified as areas of agreement.
• The concept of mutual recognition is discussed in the context of different supervisory approaches.
• The EBIC highlights the need for ongoing monitoring of practical interpretations of regulations to ensure consistency across the European banking sector.

Conclusion

The EBIC’s position reflects a strong commitment to the principles of a unified European banking market and consistent regulatory practices. Their detailed recommendations and clarification on the use of categories and mutual recognition aim to contribute to the harmonization of the CRD and enhance transparency and comparability in banking supervision across the EU.