EBA欧洲银行-CP34_BNP-Paribas_cover-letter_2页_84kb

BNP Paribas Contribution to CEBS' Guidelines for the Operational Functioning of Colleges (CP 34)

Core Content

BNP Paribas has provided a contribution to the CEBS' Guidelines for the operational functioning of colleges (CP 34), expressing its support for the proposed framework and offering specific recommendations.

Main Views and Key Points

• Support for the Guidelines:
  BNP Paribas welcomes and supports the CEBS-drafted guidelines, which aim to optimize supervision within the legislative framework. The document emphasizes the central role of the consolidating supervisor and promotes enhanced coordination and cooperation among supervisors in the execution of host powers.

• Flexibility of the College:
  The bank supports the flexibility of the college structure, provided that the composition and roles of different constellations within the college are clearly defined. This clarity is essential for effective supervision and decision-making.

• Role of the Consolidating Supervisor:
  BNP Paribas advocates for the consolidating supervisor to play a leading role in organizing and operating the college. This role is critical for ensuring a unified and coherent approach to group supervision.

• Enhanced Dialogue:
  The bank supports a wide and open dialogue between college members and the supervised group. This dialogue is necessary to provide company information and supervisory feedback, thereby improving transparency and cooperation.

• Collaborative Decision-Making:
  BNP Paribas emphasizes that supervisors should work together constructively to reach objective joint decisions that reflect the overall risk profile of the supervised institution. This should apply to all areas of prudential group supervision, including Pillar 1, Pillar 2, and reporting requirements.

• Clarification of Relationships:
  The bank calls for a clear delineation of the relationship between the college and regulatory bodies such as CEBS, EBA, and the European Systemic Risk Board (ESRB). It believes that the college is the appropriate body to assess and respond to the concrete situations of individual groups, whether in normal operations or during emergencies.

Key Information

• Author: Christian Lajoie, Co-Head of Group Public and Prudential Affairs at BNP Paribas
• Date: 31 March 2010
• Recipient: Mr Giovanni Cariuso, Chairman of the CEBS
• Contact: Mr Bart Delmartino (Email: bart.delmartino@bnpparibasfortis.com, Tel: +32-2 228 47 31)
• Purpose: To provide feedback on the CEBS' draft guidelines and highlight the importance of a well-structured and cooperative college system for effective group supervision.

Conclusion

BNP Paribas views the proposed CEBS guidelines as a valuable tool for enhancing the operational functioning of colleges. The bank supports the central role of the consolidating supervisor, the need for clear roles and responsibilities within the college, and the importance of collaborative decision-making. It also stresses the necessity of defining the relationship between the college and regulatory bodies to ensure effective and responsive supervision.