EBA欧洲银行-Public-hearing-on-recommendation-on-coverage-of-entities-200417_10页_1mb

报告摘要

Summary of the EBA Document: Recommendation of Coverage of Entities in Group Recovery Plans

Core Content

This document, published by the European Banking Authority (EBA) on 20 April 2017, addresses the need for a consistent and proportionate approach to the coverage of entities within group recovery plans (GRPs). It outlines the key issues identified in the assessment of GRPs, proposes a structured categorization of entities based on their relevance, and recommends a common supervisory guidance to avoid fragmentation and ensure effective recovery planning.

Main Issues Identified

Limited Focus on Subsidiaries: Current GRPs often emphasize the parent entity and overlook the importance of subsidiaries, which can reduce the credibility and effectiveness of the recovery plan.
Information Gaps: Competent authorities (CAs) have historically requested detailed recovery plans for subsidiaries, but if these are not adequately reflected in the GRP, critical elements may be missed.
Inconsistent Analysis: There is a lack of uniformity in how CAs assess the depth and extent of coverage for different entities within a group.

Key Recommendations

Defining Appropriate Coverage

A common supervisory guidance is essential to ensure consistency in the coverage of entities within GRPs.
The guidance aims to provide a framework for home and host supervisors to align their expectations and avoid a fragmented approach.

Categorization of Entities

The EBA proposes a proportional approach based on the relevance of entities to the group and the local financial system:

Group-relevant entities: These entities are central to the group's operations and should be covered in detail across all sections of the GRP. Recovery options and scenarios must ensure the continuity of critical functions and core business lines.
Locally relevant entities: These entities are important for the local economy or financial system. They require a level of coverage that ensures the preservation of critical functions, with some flexibility in governance and scenario analysis.
Less relevant entities: These entities have a minimal impact on the group and the local financial system. Their coverage should be concise, typically through a chart or table, and focus on their role within the group's strategy and the transmission of distress information to the parent level.

Treatment of Branches

Group or locally relevant branches: Should be included in the GRP either as part of the parent entity or as separate entities, ensuring that branch-specific information is captured.
Non group or locally relevant branches: Do not need to be identified separately in the GRP but should be included in the context of their parent entity.
"Significant +" branches: Should be covered in the GRP as either group or locally relevant entities.

Transitional Phase

A transitional phase is proposed to ensure a coordinated and comprehensive approach to GRPs, allowing for the migration of existing individual recovery plans into the group framework under joint decisions.

Pragmatic Approach and Temporary Solution

A pragmatic approach is suggested for the temporary integration of individual recovery plans into the GRP, provided the following conditions are met:
- The individual plans are necessary to preserve existing recovery planning information at the local level.
- The plans are communicated to the consolidating supervisor and are fully consistent with the group recovery plan.

Questions for Discussion

The EBA invites further discussion on the following points:

Views on the proportional approach and the identification of three categories of entities.
Opinions on the level of coverage for group-relevant and locally relevant entities.
Experience in dealing with appropriate coverage of entities within recovery plans.
Identification of the most critical challenges faced in implementing these requirements.