EBA欧洲银行-End-of-term-of-office-report-of-the-EBA27s-Banking-Stakeholder-Group-8-.._19页_717kb

Summary of the BSG III End of Term of Office Report (ETOR)

Core Content

The End of Term of Office Report (ETOR) of the European Banking Authority (EBA) Banking Stakeholder Group (BSG III) outlines the contributions and activities of the BSG from April 2016 to October 2018. The BSG, composed of 30 members from six constituencies (credit institutions, consumers, academics, users of banking services, employees, and SMEs), serves as an official advisory group to the EBA, contributing to the development of a Single Rulebook for the EU banking sector and promoting supervisory convergence and financial stability.

The report highlights the strategic and proactive role of the BSG in anticipating the EBA’s needs and offering insights that help shape regulatory and supervisory frameworks. It also reflects on the challenges posed by Brexit, the reform of European supervisory agencies, and the progress toward banking union.

Main Goals and Objectives of the BSG

• To support the EBA in achieving its mission of a Single Rulebook.
• To promote financial stability, consumer protection, and supervisory convergence.
• To provide strategic input and technical expertise in areas such as capital, liquidity, risk management, recovery and resolution, and FinTech.
• To engage in joint activities with other stakeholder groups of the ESAs, particularly ESMA and EIOPA.

Key Activities and Outputs

Technical Working Groups (TWGs)

BSG III established five technical working groups to address specific regulatory and supervisory issues:

1. Capital, Liquidity and Risks (CLR TWG)

   • Focused on technical Level 2 measures related to capital and liquidity requirements.
   • Drafted responses to several EBA consultation papers, including guidelines on PD estimation, LGD, interest rate risk, and stress testing.
   • Discussed the implications of Basel III reforms, Brexit, and risk reduction measures.

2. Recovery, Resolution and Systemic Issues (RRSI TWG)

   • Addressed topics such as MREL, bail-in tools, and resolution planning.
   • Participated in discussions on valuation for resolution, TLAC implementation, and creditor hierarchy.

3. Supervision, Governance, Reporting and Disclosure (SGRD TWG)

   • Dealt with supervisory frameworks, internal governance, and transparency requirements.
   • Responded to consultations on fraud reporting, payment account regulations, and disclosure of NPLs.
   • Engaged in the implementation of IFRS 9 and the Pillar 2 framework.

4. Consumer Protection

   • Focused on consumer data use, transparency in fees, and protection against unfair practices.
   • Addressed issues such as dynamic currency conversion (DCC), floor-rate clauses, and cross-border transaction costs.
   • Emphasised the need for harmonised rules to ensure a level playing field and consumer rights.

5. Payments, Digital and FinTech

   • Analyzed FinTech developments and payment innovations.
   • Produced a report on regulatory sandboxes, which is a key element of the EBA's FinTech Roadmap.
   • Participated in the EBA's Q&A review process to ensure consistent application of the Single Rulebook.

Additional Activities

• The BSG collaborated with ESMA and EIOPA stakeholder groups on the review of the ESAs.
• Participated in public consultations on transparency and fees in cross-border transactions and regulatory sandboxes.
• Engaged in the Q&A implementation review to improve the consistency and effectiveness of regulatory application across the EU.
• Provided strategic input on regulatory equivalence and market access in the context of Brexit.
• Supported the EBA's relocation to Paris, which had significant implications for its operations.

Challenges and Recommendations

• Brexit created uncertainty and challenges for financial institutions and supervisory authorities, requiring harmonised rules and close cooperation.
• The ESAs review by the European Commission led to public consultations and joint responses from the BSG and other stakeholder groups.
• The banking union progress included discussions on non-performing loans (NPLs), sovereign bond-backed securities, and the Single Resolution Fund, although some initiatives were halted due to lack of political consensus.
• The EBA's Q&A process was under review to improve its efficacy and consistency.

Lessons and Future Outlook

• The BSG has evolved to become more strategic and proactive, focusing on anticipating needs and providing forward-looking insights.
• Consensus-building remains a core value, but minority views are also included in reports when necessary.
• The BSG continues to be a valuable asset for the EBA, contributing to regulatory clarity, supervisory convergence, and consumer protection.
• The report serves as a legacy for future BSG members, aiming to improve the functioning and impact of the group.

Conclusion

The BSG III has played a crucial role in supporting the EBA's regulatory and supervisory efforts, particularly in the context of banking union, FinTech innovation, and the adverse impact of Brexit. The group's multidisciplinary composition and proactive approach have significantly enhanced the quality and impact of its contributions. The report provides insights, recommendations, and lessons learned to guide future BSG activities and ensure the continuity of its contributions to the EBA.