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CEBS Consultation Paper Feedback Summary

Core Content

The CEBS (Committee of European Banking Supervisors) published a consultation paper (CP29) in September 2009, proposing an extension of its supervisory disclosure framework. The consultation period lasted one month, ending on 16 October 2009. A public hearing was held on 5 October 2009. During this period, two written responses were received, and one was submitted after the consultation period, which was still considered.

The feedback table (Annex 1) summarises the main comments received and CEBS's responses to them.

Main Comments and CEBS Responses

1. National Options and Discretions

• Comment: One respondent requested that the precise implementation of the 0% risk weight for credit risk exposures with central counterparties be disclosed on the “List of National Discretions.”
• CEBS Response: CEBS acknowledges that the implementation of this provision may vary across EEA member states. Therefore, it is reasonable to include this information in the section on national options and discretions.
• Proposed Amendment: CEBS will include this disclosure in the national options and discretions section. Competent authorities that have applied this supervisory decision (“A” for Applied at CEBS level) are expected to disclose on their national homepages which exposures are eligible for a 0% risk weight.

2. General Comments

• Comment: CEBS members were requested to provide hyperlinks to national provisions within the framework. However, there was concern that such links should be used cautiously to avoid unnecessary duplication of work and to reduce the burden on both national and CEBS levels.
• CEBS Response: CEBS supports the use of hyperlinks but recommends that they be used on an exception basis to prevent unnecessary duplication and to ease the updating process. This approach ensures that outsiders can understand how each Member State has implemented European legislation without additional research.
• Proposed Amendment: No amendments were proposed to the text.

3. Interpretation of National Discretions

• Comment: Some respondents suggested that a common framework for interpreting national discretions should be included at the CEBS level to ensure consistency across member states.
• CEBS Response: CEBS stated that it does not have a mandate to provide a common interpretation of national discretions. Instead, it recommends that national discretions and options be described briefly, which provides a sufficient basis for harmonised presentation across CEBS members.
• Proposed Amendment: No amendments were proposed to the text.

Key Information

• Consultation Period: 1 month (from September to October 2009).
• Public Hearing: Held on 5 October 2009.
• Number of Responses: Two written responses were received during the consultation, and one was submitted after the period.
• Framework Extension: The proposed extension aims to enhance transparency and harmonisation in the implementation of credit risk exposures with central counterparties.
• Hyperlink Usage: CEBS recommends using hyperlinks to national provisions on an exception basis to avoid duplication and ensure clarity for outsiders.
• National Discretions: CEBS believes that brief descriptions of national discretions are sufficient for harmonised presentation, and does not intend to introduce a common interpretation framework.

Conclusion

The feedback on CEBS's consultation paper highlights the importance of transparency and consistency in the implementation of the supervisory disclosure framework across the EEA. CEBS has responded to the concerns by committing to include specific disclosures on national discretions and by recommending a cautious approach to hyperlink usage. These measures aim to balance the need for clarity with the practicalities of maintaining an efficient and harmonised framework.