EBA欧洲银行-UCG_CP39-public_4页_175kb

报告摘要

UniCredit Group's Reply to the CEBS CP 39 on Risk-Based Capital Adequacy of Cross Border Groups

Core Content

UniCredit Group's response to the CEBS CP 39 document outlines its support for enhancing the European Banking Authority (EBA) role in cross-border banking supervision. The group acknowledges the necessity of a stronger, more coordinated supervisory framework to ensure financial stability and a level playing field across the EU. They emphasize the importance of a unified approach to capital adequacy and stress testing, aligned with Basel II Pillar 2 principles, and the need for a robust crisis management architecture.

Main Views and Key Points

1. Empowerment of EBA

UniCredit supports the idea of empowering EBA ex-ante with a coordinating and authoritative role.
EBA should have the final say and binding powers in settling disagreements among competent authorities.
A stronger EBA is essential for effective crisis management in cross-border banking groups.

2. Role of the Parent Company

The parent company should serve as the single entry point for implementing joint decisions by the Colleges of Supervisors (CoS).
It must be formally recognized and equipped with the necessary powers and tools to enforce these decisions.
The parent company is best positioned to understand the group's business model and systemically important activities, making it a key player in crisis management.

3. Convergence of Supervisory Expectations

UniCredit advocates for greater convergence in supervisory expectations, particularly in ICAAP (Internal Capital Adequacy Assessment Process) and SREP (Supervisory Review and Evaluation Process) reporting.
This convergence would help reduce discrepancies between reports prepared for consolidating and local supervisors.
They support the alignment of these processes with a common Pillar 2 framework, including consistent stress test analyses and timelines.

4. Cross-Border Arrangements

The group emphasizes the need for more explicit cross-border arrangements for burden sharing, national deposit guarantee schemes, and recovery/resolution funds.
These arrangements are seen as a precondition for a stable and effective European financial supervisory framework.

5. National Discretion and Accounting Principles

National discretion and differences in accounting principles and definitions should be minimized to ensure a level playing field.
They encourage the CoS to define how intra-group positions should be treated in capital requirements, including the possibility of a consolidated approach where all intra-group positions are eliminated.

6. Legislative Constraints and External Entities

Considering existing legislative constraints, UniCredit suggests reaching a common agreement on the role of entities acting on supervisors' behalf, such as external auditors.
They also note that while they support the general objectives, some detailed proposals may require changes to national legislation or supervisory regimes.

Conclusion

UniCredit Group believes that a more integrated and coordinated European supervisory framework is crucial for maintaining financial stability and ensuring a fair regulatory environment. They advocate for the EBA to play a central role in this process, while also recognizing the importance of the parent company in implementing joint decisions. The group supports the convergence of supervisory expectations and the development of cross-border mechanisms, but remains cautious about certain detailed proposals that may require national-level adjustments.