2014年-EBA欧洲银行管理局_BSG_2013_Final_Report_25页_576kb

Summary of the End of Term of Office Report of the Banking Stakeholder Group (BSG) of the EBA

Core Content

The End of Term of Office Report of the Banking Stakeholder Group (BSG) of the European Banking Authority (EBA) covers the first term of the BSG, which ran from March 2011 to September 2013. This report outlines the BSG's structure, functions, key contributions, and areas of focus during its tenure, as well as its assessment of the effectiveness of its work and future recommendations.

Main Tasks and Structure of the BSG

The BSG was established to facilitate stakeholder consultation in the EBA's regulatory processes. It was formed by the EBA's Board of Supervisors (BoS) in accordance with Article 37 of the EBA Regulation.

• Membership: The BSG consisted of 30 members representing six constituencies: credit and investment institutions, employees, consumers, SMEs, users of banking services, and independent top-ranking academics. Members were selected through a rigorous process.
• Meetings: The BSG was required to meet at least four times a year, with the possibility of more frequent meetings. Attendance at two consecutive meetings was considered a failure to perform duties, which could lead to replacement.
• Functions: The BSG's primary role was to advise the EBA on regulatory technical standards (RTS), implementing technical standards (ITS), and guidelines, as well as to contribute to the development of a common supervisory culture and market intelligence.

BSG Output

The BSG provided detailed opinions and advice on numerous EBA consultation papers and technical standards, including:

• Regulatory Technical Standards (RTS):

  • Draft RTS on Own Funds (EBA/CP/2012/02)
  • Draft RTS on Capital Requirements for Central Counterparties (CCPs) (EBA/CP/2012/08)
  • Draft RTS on Conditions for Assessing the Materiality of Extensions and Changes of Internal Approaches for Credit, Market, and Operational Risk (EBA/CP/2013/02)
  • Draft RTS on Own Funds (Part III) (EBA/CP/2013/17)
  • Draft RTS on Additional Liquidity Outflows (EBA/CP/2013/19)

• Implementing Technical Standards (ITS):

  • Draft ITS on Disclosure for Own Funds (EBA/CP/2012/04)
  • Draft ITS on Supervisory Reporting Requirements for Leverage Ratio (EBA/CP/2012/06)
  • Draft ITS on Additional Liquidity Monitoring Metrics (EBA/CP/2013/18)

• Discussion Papers (DP):

  • DP on Prudent Valuation (EBA/DP/2012/03)
  • DP on Defining Liquid Assets in the LCR under the draft CRR (EBA/DP/2013/01)
  • DP on Retail Deposits subject to Higher Outflows for Liquidity Reporting (EBA/DP/2013/02)

• Other Outputs:

  • Position Paper on "New Bank Liquidity Rules – Dangers Ahead" (October 2012)
  • Opinion on the Joint Committee's proposals on FICOD (JC/CP/2012/02)
  • Input to the EBA's Report on Consumer Trends 2012
  • Opinion on Good Practices for ETF Risk Management (EBA/Op/2013/01)
  • Opinion on the Joint Position of the ESAs on Product Oversight and Governance

Technical Working Groups

To enhance efficiency and technical depth, the BSG established four Technical Working Groups:

1. Bank Capital Working Group (Coordinator: Louise Lindgren)
2. Bank Liquidity Working Group (Coordinator: Andrea Resti)
3. Consumer Protection Working Group (Coordinator: Robin Jarvis)
4. Systemic Issues Working Group (Coordinator: Sony Kapoor)

These groups were formed to address key regulatory priorities and to provide detailed input on technical standards. Their work was conducted through email and conference calls, with draft texts circulated to all BSG members and discussed in plenary meetings when possible. The final reports were issued in the name of the BSG as a whole.

Key Issues and Emerging Themes

• The BSG focused heavily on capital and liquidity regulations due to the ongoing banking crisis and the need for enhanced stability.
• It was concerned with the implications of the Single Supervisory Mechanism (SSM) and the European Banking Union.
• The BSG also engaged with consumer protection, SMEs, and market trends, ensuring that these areas were not marginalised.
• It contributed to the development of a single rulebook across the EU and promoted a common supervisory culture to reduce regulatory arbitrage.

Assessment of the BSG

The BSG performed well during its first term and developed a constructive relationship with the EBA. However, it identified several areas for improvement:

• Earlier Consultation: The EBA should consult the BSG earlier in the regulatory process, ideally before issuing consultation papers.
• Feedback Mechanism: The BSG would welcome more explicit feedback from the EBA on its opinions.
• Resources and Support: More resources should be allocated to the BSG and its Technical Working Groups to enhance their effectiveness.
• Data Access: Greater access to EBA's internal data (such as Pillar 3 data) would improve the quality of regulatory input.
• Joint Meetings: The BSG and EBA's BoS meetings should be improved to facilitate more effective two-way engagement.

Conclusion

The BSG was instrumental in shaping the regulatory landscape of the EU banking sector during its first term. It successfully engaged with a wide range of stakeholders and contributed to the development of key regulatory standards. The report acknowledges the contributions of EBA staff and the collaborative spirit of the BSG members. It also highlights the importance of continued cooperation and the potential for the BSG to play a vital role in future regulatory developments.

Key Recommendations

• The EBA should engage the BSG earlier in the regulatory process.
• A more robust feedback mechanism should be established.
• Additional resources and support should be allocated to the BSG and its working groups.
• Improved access to EBA data would enhance the quality of the BSG's contributions.
• Joint meetings with the EBA's BoS should be made more effective and structured for two-way dialogue.