EBA欧洲银行-FBF_CP10_5页_479kb

报告摘要

FBF Response on Guidelines for AMA and IRB Approaches (CP10) Summary

Core Content

The French Banking Federation (FBF) has responded to the CEBS consultation document on the implementation, validation, and assessment of the Advanced Measurement Approach (AMA) and the Internal Ratings-Based (IRB) approach. The FBF appreciates the CEBS objective of promoting convergence in the application of these approaches across the European banking sector but expresses concerns regarding the clarity, practicality, and consistency of the proposed guidelines.

Main Views and Key Concerns

1. Purpose and Scope of the Document

The FBF is uncertain about the purpose of the document and the intended use by regulators.
It questions whether the guidelines are meant to be followed strictly, partially, or ignored, and whether they allow for national discretion.
The FBF hopes the document is a starting point and urges CEBS to clarify its intentions and definitions.

2. Pre-Validation Phase

The industry is currently in a pre-validation phase, with national supervisors setting requirements based on the current application practices.
The FBF recommends that CEBS take this into account and integrate these pre-validation efforts into the overall validation process.

3. Prescriptive Nature of the Guidelines

The proposed guidelines are seen as overly prescriptive and more detailed than the Capital Requirement Directive (CRD).
This level of detail is considered burdensome and not helpful for practical implementation.
Some terms in the document are confused with those in the CRD, leading to potential misinterpretations.

4. Internal Governance and Documentation

The documentation requirements for internal practices are excessive and not aligned with the actual needs of the banking industry.
The FBF believes that the guidance is too intrusive and may interfere with the responsibilities of both supervisory and management bodies.
They suggest that the guidance should be made coherent with the BCBS consultation on corporate governance.

Specific Remarks

Section	Remarks
§23	The sentence about supervisors imposing stronger requirements should be removed. It creates an open door for excessive regulation.
§38	The interaction between pre-application and application phases is unclear. Banks do not want to go through multiple qualification processes.
§47	The word "legally" should be deleted due to confusion.
§48	The application form should be based on the pre-validation phase and not replicate previous work. The term "official and legally binding statement" is unclear and unfair. A "qualification certificate or passport" is suggested to improve information flow between supervisors.
§132	The reference to pricing PDs should be removed. Regulators should not focus on pricing policies.
§133	The requirement for detailed documentation of differences is problematic. It should be replaced with a suggestion to explain differences in general documentation and apply appropriate internal controls.
§146-149	The definition of the experience test period is unclear. It needs to be better defined to avoid confusion.
§205	The industry does not agree with the detailed definition of "work out" and "collection cost." The concept of "indirect cost" is debatable and not standard.
§240 and after	The text only addresses undrawn amounts of commitments, not the calculation of own estimates of CF on guarantees.
§258	Banks should be allowed to mix internal and supervisory estimates in a single legal entity, as long as they are applied differently for different categories.
§306	Similar to §133, this section should not be interpreted as a requirement for specific controls and validation by independent parties. It should be a recommendation for appropriate quality controls.
§352	The term "quantitative validation" for Low Default Portfolios is ambiguous. Benchmarking may be one technique, but it is not feasible without public data.
§437 and §448	Examples should be removed as they may be considered local requirements.
§452	The reference to section 3.5.1 is unclear and should be adapted to the AMA approach.
§455 & §456	The terms "weighting" and "weighted" are redundant and should be removed. "Combined" is sufficient.
§456	The second bullet point is redundant and should be deleted.
§481 (5th bullet point)	External loss experience should not be systematically included in reporting. Instead, it should be mentioned only when appropriate.

Conclusion

The FBF emphasizes the need for clarity, coherence, and practicality in the CEBS guidelines. They advocate for a balanced approach that allows for necessary flexibility while ensuring that the guidelines are aligned with the principles of the CRD and the BCBS corporate governance consultation. The FBF recommends that CEBS review the guidelines to ensure they are not overly burdensome and that they support the banking industry's efforts in risk management and regulatory compliance.

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