EBA欧洲银行-EBA-BSG-2016-048-28draft-Minutes-of-24-october-meeting29_9页_229kb

Banking Stakeholder Group – Summary of Meeting Minutes (EBA BSG 2016 048)

Meeting Overview

• Date: 24 October 2016
• Time: 9:30–16:30
• Location: London
• Participants: Representatives from various financial institutions, associations, and academic bodies.
• EBA Staff Present: Andrea Enria (Chairperson), Adam Farkas, Piers Haben, and other EBA officials.

Core Content and Main Points

1. Welcome and Agenda Approval

• The EBA Chairperson welcomed the BSG members.
• The agenda and minutes from the 22 June 2016 meeting were approved.

2. BSG Update on Recent Developments

A) Joint Reply to Consultation Papers

• The BSG Chairperson proposed a joint reply to common Consultation Papers (CPs) from the three ESAs (EBA, ESMA, ESRB), provided that procedures are defined to avoid coordination issues.
• BSG members supported this initiative on a case-by-case basis, considering cost-benefit implications.

B) Technical Working Groups Activities

• Five Technical Working Groups presented their work since the last meeting.
• Two new Ad-Hoc Working Groups were established:
  • "Regulatory Sandboxes" (coordinated within the Fintech and Payments Working Group)
  • "Dynamic Currency Conversion" (coordinated within the Consumer Protection Working Group)

C) Brexit Discussion

• The BSG expressed concerns about equivalence and consumer protection in the context of Brexit.
• It was decided that further discussion on Brexit issues would not be useful at this time, and the Chairperson would seek members' views later.

3. Disclosure Requirements under Part Eight of Regulation (EU)

• The EBA published a Consultation Paper on draft Guidelines for regulatory disclosure requirements.
• The BSG decided not to issue an Opinion, but one member proposed amendments.
• The rationale for including insurance participation disclosures was explained, emphasizing comparability and financial stability.
• BSG members supported the EBA's position, recognizing the importance of credibility in financial reporting.

4. EBA General Developments Update

A) Policy Research Workshop on Competition in Banking

• The 5th EBA Policy Research Workshop on "Competition in banking: implications for financial regulation and supervision" was mentioned.

B) Basel Committee Coordination

• The EBA coordinated a common European position at the Basel Committee.
• Work included a wide range of regulatory products and the final MREL report.

C) MREL Report

• The MREL report was nearing completion, focusing on intragroup issues and EU as a single jurisdiction.
• Topics included subordination, exemptions, disclosure, and reporting of MREL.

D) Panama Papers and Internal Governance

• The EBA participated in a hearing on the Panama Papers and launched a working plan to review cases.
• Internal governance was highlighted as an area of focus, with potential overlap with other reports.

E) IFRS 9 Impact Assessment

• An impact assessment on IFRS 9 was planned, aiming to evaluate its effect on regulatory own funds.
• The report would also assess the progress of banks in implementing IFRS 9 and identify potential future effects.

F) Post-Mortem on Stress Tests

• A post-mortem exercise on past stress tests was mentioned, with potential discussion at the next BSG meeting.

G) Investment Firms Report

• The EBA published a report on investment firms in 2015, and the Commission requested technical advice.
• The EBA proposed a three-tier approach for investment firms, with different requirements based on size.
• A discussion paper was to be published to complement the report.

H) Consumer Protection Work

• The EBA planned to publish a Proportionality Paper by year-end and asked the BSG to contribute.
• The Consumer Trends Report for 2017 was postponed due to reprioritization.

5. Consumer Protection, Financial Innovation, and Payments Work

• The EBA presented a Consultation Paper on draft Technical Standards under the Payments Account Directive (PAD), focusing on:
  • Standardized terms and definitions for payment account services
  • Pre- and post-contractual disclosure documents (Fee Information Document and Statements of Fees)
• The methodology for consumer testing, including the selection of Poland and the UK for "face to face" tests, was discussed.
• BSG members raised concerns about the scope of the standards and the flexibility for Competent Authorities (CAs).
• The Consumer Day in Paris was highlighted, with key themes including supervisory convergence, Big Data, and consumer protection.
• The next Consumer Day was planned to take place in Czech Republic, involving consumer representatives as speakers and participants.

6. Other Regulatory Deliverables

A) Liquidity Coverage Ratio (LCR) Report

• The EBA published its first LCR report under the Delegated Act (DA), based on data from 31 December 2015.
• The report compared the EU LCR with the Basel III framework, focusing on:
  • High-quality liquid assets (HQLA)
  • Outflows and inflows
  • Currency mismatch
• The 100% minimum binding standard was not deferred until 1 January 2019.
• BSG members suggested expanding the scope of the report to include the impact on lending and the real economy.

B) Internal Governance Consultation Paper

• The EBA presented draft Guidelines on internal governance, aiming to address weaknesses identified during the crisis.
• Key areas included:
  • Management body duties and responsibilities
  • Board committees (risk, nomination)
  • "Know your structure" and transparency for complex structures
  • The three lines of defense model
  • Whistleblowing procedures
• The "comply or explain" process was emphasized for harmonization and supervisory convergence.
• Diversity in the selection of management board members was included, not limited to gender but also educational background and geographical origin.
• CAs were to be responsible for following up on the whistleblowing framework.

C) PD and LGD Modelling Guidelines

• The EBA presented draft Guidelines on PD and LGD estimation and the treatment of defaulted assets.
• These guidelines were part of the broader review of the IRB Approach.
• A 3-month consultation period was planned, with a qualitative survey to assess potential impacts.
• The guidelines aimed to target non-risk based variability and preserve risk sensitivity in internal models.
• A link was made to IFRS 9, with the expectation that banks would base their models on IRB experience.

Item 7: Agenda for the Joint BoS/BSG Meeting

• BSG members briefly discussed topics to be presented at the Joint BoS/BSG meeting the following day.

Key Information and Conclusions

• The BSG emphasized the importance of proportionality, harmonization, and supervisory convergence.
• Collaboration with other ESAs (ESMA, ESRB) was encouraged, particularly for joint responses to CPs.
• The EBA's work on disclosure, internal governance, and risk modeling was central to the meeting.
• There was a focus on consumer protection, financial innovation, and regulatory impact assessments.
• The Panama Papers and funding plans were discussed as important topics for transparency and risk assessment.