2014年-EBA欧洲银行管理局_FinalReportonregulatoryimplementationofPillar3_20页_384kb

Summary of the CEBS Report on Regulatory Implementation of Pillar 3

Key Findings

• The report provides an overview of the regulatory implementation of Pillar 3 disclosures in the EU, based on CEBS members' responses to a survey.
• It highlights the main issues and concerns related to the application of Pillar 3 requirements, particularly regarding the scope of disclosure and the relationship between Pillar 3 and accounting disclosures.
• The findings reveal differences in how countries apply the disclosure requirements, especially for subsidiaries of EU parent institutions.
• CEBS has identified the need for follow-up work to address these issues, particularly in relation to the scope of application and the alignment of Pillar 3 with accounting standards.
• The report was discussed with industry participants at a Pillar 3 workshop on 7 December 2007, and it was generally accepted by them.
• Some industry representatives expressed concerns about the complexity and cost of Pillar 3 disclosures, and the potential for misinterpretation by market users.
• CEBS plans to collaborate with the industry to explore practical solutions to these challenges, with expected outcomes in 2008.

Core Content and Main Issues

I. Scope of Application of Pillar 3 Disclosure Requirements

• Article 72.1 and 72.2: These articles require EU parent credit institutions and their significant subsidiaries to disclose certain capital-related information.
• Supervisory Intervention:
  • 7 countries set quantitative criteria for significant subsidiaries.
  • 1 country used qualitative criteria.
  • 5 countries used both.
  • 9 countries (including some with supervisory influence) do not intervene.
• Disclosure Requirements for Subsidiaries:
  • 23 countries apply limited disclosure to subsidiaries.
  • 4 countries (BG, HU, LT, PT) require full disclosure from all local entities.
  • 6 countries (mostly host countries) require all entities to disclose the full set of information.
• Industry Concerns:
  • Some countries have broader disclosure requirements than the Directive.
  • Industry representatives argue that Pillar 3 disclosures should be the responsibility of the firms, not supervisors.
  • They believe that the cost of disclosure outweighs its value for most local stakeholders.
  • They prefer group-level disclosures over subsidiary-specific ones.

II. Disclosure Policy and General Concepts

• Formal Disclosure Policy: Article 145.3 of the Directive requires credit institutions to adopt a formal policy for disclosures.
• Supervisory Guidance:
  • Most countries do not provide specific guidance on disclosure policy structure or content.
  • 12 countries require submission of the policy to supervisors.
  • 6 countries require its publication.
  • 2 countries require both.
• Link with Internal Methodologies:
  • 12 countries consider disclosure policy development part of the internal methodology approval process.
  • 11 countries see it as a separate issue.
• Materiality and Proprietary Information:
  • Most countries do not impose specific supervisory criteria.
  • Some provide case-by-case guidance.
  • No follow-up action is recommended in this area.

III. Other Issues

• Frequency of Disclosure:
  • 23 countries apply annual disclosure.
  • 6 countries allow more frequent disclosure (semi-annual or mid-year).
  • The industry prefers a consolidated approach to determining frequency.
• Medium, Location, and Verification:
  • 15 countries do not prescribe specific media or locations.
  • 13 countries do, with bank websites being the most common.
  • 7 countries require specific verification methods, mostly through external auditors.
  • The industry is concerned that verification requirements may conflict with internal risk management processes and increase costs.
• Standardised Formats and Prudential Reports:
  • These areas were considered but not as pressing.
  • No major concerns were raised, except for the relationship between accounting and Pillar 3 disclosures.

Key Relationships and Concerns

• Accounting vs. Pillar 3 Disclosures:
  • There is a need for consistency between the two types of disclosures.
  • IFRS 7 disclosures are not expected to be repeated for Pillar 3 compliance.
  • Some countries are considering guidance on this matter.
  • The industry believes the two should be complementary, not inconsistent.
• Proportionality Principle:
  • Not a major concern.
• Supervisory Actions in Case of Non-Disclosure:
  • Not a major concern.

Follow-Up Work

• Focus Areas:
  • Further investigation into the application of articles 72.1 and 72.2 to subsidiaries.
  • Exploring a compromise solution where limited disclosure is provided alongside subsidiary financial statements.
  • Monitoring the relationship between Pillar 3 and accounting disclosures.
• Collaboration:
  • CEBS will work closely with the industry and users of bank disclosures.
  • The outcome of this work is expected by the end of 2008.
• Good Practices Paper:
  • A potential future project could involve developing a good practices paper on Pillar 3 disclosures.
  • Such a paper would need coordination with other supervisory bodies like the Basel Committee.

Conclusion

• The report identifies key areas of concern in the implementation of Pillar 3 disclosures.
• It emphasizes the importance of aligning Pillar 3 with accounting standards and ensuring consistency.
• CEBS will continue to monitor and engage with the industry to address these issues and improve the regulatory environment for market discipline.