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NVB Reaction to CEBS CP39 Guidelines on Joint Assessment of SREP Elements

Core Content

The Dutch Banking Association (NVB) has submitted feedback on the CEBS Consultation Paper 39 (CP39) concerning the joint assessment of the elements covered in the Supervisory Review and Evaluation Process (SREP) and the joint decision on the capital adequacy of cross-border banking groups. The NVB acknowledges the importance of the guidelines in the context of EU banking supervision integration and supports the transition of CEBS into the EBA, as well as increased cooperation among competent authorities in supervisory colleges.

Main Views

The NVB emphasizes the need for improvements in the final guidance, particularly in the following areas:

1. Achieve Convergence of the ICAAP Process

• The NVB appreciates the explicit references to the ICAAP (Internal Capital Adequacy Assessment Process) and SREP processes.
• They highlight the importance of standardizing ICAAP expectations across the supervisory college to ensure comparability of reports across countries.
• This standardization would enhance the efficiency of both the supervisory college and the cross-border banking group.

2. Opportunity to Learn from Other College Members

• The NVB believes that cooperation among competent authorities in supervisory colleges offers a valuable opportunity to exchange methods and approaches.
• This exchange promotes understanding and trust among members of the college.
• They suggest that cross-border banking groups should be allowed to directly address the supervisory college to stimulate dialogue and improve the effectiveness of the college's operations.

3. Importance of Feedback to the Banking Group

• The NVB underscores the necessity of providing high-quality feedback to cross-border banking groups.
• Timely and complete feedback is essential for the group to incorporate the college's advice into its risk management practices.
• This ensures that the SREP process is not only a regulatory exercise but also a constructive tool for improving financial stability.

Key Information

• Document Title: CEBS Consultation Paper 39
• Date: 09 July 2010
• Reference: BR1193
• Sender: Dutch Banking Association (NVB)
• Recipient: Committee of European Banking Supervisors (CEBS)
• Supporting Organization: The NVB fully supports the feedback provided by the European Banking Federation (EBF).

Conclusion

The NVB concludes that the consultation paper is a positive step towards harmonizing banking supervision in the EU. However, they recommend that the final guidance should place more emphasis on the convergence of ICAAP processes, the opportunity for learning and dialogue between competent authorities and cross-border groups, and the importance of timely and complete feedback to the banking groups. These elements would enhance the effectiveness and efficiency of the supervisory process.