EBA欧洲银行-CP24_ESBG_4页_193kb

报告摘要

ESBG Response to CEBS Consultation on High-Level Principles for Risk Management (CP24)

Core Content

The European Savings Banks Group (ESBG) has responded to the CEBS consultation on "High-level principles for risk management" (CP24), issued on 6 July 2009. The ESBG acknowledges the initiative to consolidate existing risk management principles and guidelines into a comprehensive guidebook aligned with the structure of Annex V of the Capital Requirements Directive (CRD). However, the ESBG believes that the current presentation of CP24 does not fully achieve this goal.

Main Views and Recommendations

1. Comprehensive Guidebook and Overlap Issues

ESBG supports the idea of consolidating risk management principles into a single guidebook.
It argues that CP24, as a separate set of stand-alone principles, lacks the comprehensive nature required.
The ESBG recommends that CP24 be supplemented with references to other relevant risk management principles and guidelines to ensure a complete understanding.
It also suggests that principles from other regulatory bodies, such as the Basel Committee, should be included for a broader perspective.

2. Risk Appetite and Risk Tolerance

The introductory sentence in paragraph 13 is deemed unnecessary and should be removed.
The ESBG believes that "risk appetite" and "risk tolerance" are largely synonymous and should be treated as such.
There is a redundancy between paragraphs 13 and 15, and the ESBG recommends deleting the overlapping part.
The second sentence in paragraph 15 is considered irrelevant and should be removed.
The ESBG suggests that the requirement for "constant" review of risk measurement should be changed to "regular" to make it more realistic.

3. Role of the Chief Risk Officer (CRO) and Risk Management Function

ESBG agrees that the CRO and the risk management function should have expertise matching the institution's risk profile.
It recommends that the first two sentences in paragraphs 21 and 22 be combined and followed by a clear description of the tasks assigned to the CRO and the risk management function.

4. Risk Models and Integration of Risk Management Areas

The concept of "integrated treatment of risk" in paragraph 29 is understood as having a broad overview of relevant risks related to new products or activities.
ESBG suggests that this principle would be more appropriately placed under the section on "New product approval policy and process".
The content of paragraph 31 is considered to be largely redundant with the requirements in paragraphs 11 and 12 and should be moved to the governance section.

About ESBG

ESBG is an international banking association representing one of the largest European retail banking networks.
It comprises about one third of the retail banking market in Europe, with total assets of €5967 billion as of 1 January 2008.
ESBG represents its members' interests before EU institutions and facilitates cross-border banking projects.
Its members are typically savings and retail banks or associations thereof, often organized in decentralized networks.
These banks have been reinvesting responsibly in their regions for many decades and serve as a benchmark for corporate social responsibility activities.