EBA欧洲银行-BSG-2012-19minutes-5th-meeting-BSG-7-February-2012-_8页_141kb

报告摘要

Summary of the 5th Meeting of the Banking Stakeholder Group (BSG) - 7 February 2012

1. Core Content and Key Issues

The 5th meeting of the Banking Stakeholder Group (BSG) was held at the EBA's offices on 7 February 2012. The agenda was approved, and the main focus was on the state of the EU banking system, challenges, and key issues that require joint attention between the BSG and the European Banking Authority (EBA). The following issues were identified as critical:

Sovereign-bank inter-linkages
Increasing spread and scope of the Euro crisis
Funding difficulties, particularly lack of dollar funding
Potential pro-cyclicality of the regulatory framework and lack of transitional period
Regulation vs. resolution rules and potential substitutability
Variability of risk weights across different institutions
Macroeconomic impact of bank deleveraging
Inappropriate bank remuneration practices
Consequences of current policy measures and increasing dependence on support
Consumer protection issues, especially the diminishing availability of credit to SMEs

The EBA confirmed that its recapitalisation and stress testing exercises, along with ECB liquidity interventions, are aimed at limiting the negative sovereign-bank feedback loop and restoring market confidence. Additionally, the EBA is analyzing risk weights with a focus on SMEs and is addressing proportionality in regulatory changes.

2. EBA Draft Consultation Paper on Management Body and Key Function Holders

The EBA presented a draft consultation paper on assessing the suitability of members of the management body and key function holders. The consultation is expected to start in April 2012. BSG members made the following preliminary comments:

Difficulties in assessing skills through interviews
Need for harmonised exams and accreditations
Keeping documentation burdens reasonable
Proportionality in requirements for different institutions
Importance of a culture of lifelong learning
Concerns about management experience requirements affecting promotion opportunities

The EBA confirmed that both qualifications and experience are considered, and that proportionality is a key principle. The BSG was encouraged to provide its opinion during the consultation.

3. EBA Consultation Paper on Draft ITS on Supervisory Reporting Requirements

The EBA presented a consultation paper on draft Implementing Technical Standards (ITS) related to supervisory reporting. This concerns Articles 95 and 96 of the proposed Capital Requirements Regulation (CRR). BSG members were invited to submit comments by 20 March 2012.

Key concerns raised by BSG members included:

Proportionality of the reporting requirements
Level playing field issues in data collection across Europe and the US
Concerns about the short timeline for adapting to the ITS, especially regarding IT systems
Support for a uniform reporting framework
Concerns over remittance periods being too short
Inconsistencies between COREP and FINREP

The EBA emphasized the importance of feedback on data definitions and thresholds to reduce reporting burdens.

4. Technical Working Groups

4.1 Technical Working Group on Consumer Protection Issues (TWGCPI)

Robin Jarvis outlined the TWGCPI's structure and methodology, emphasizing cooperation with EBA's Consumer Protection Unit and Financial Services User Group (FSUG). The group agreed to select 3–4 issues for analysis based on the EBA's publication 'Financial Innovation and Consumer Protection'. BSG members also raised concerns about the adequacy of financial compensation for non-industry representatives, suggesting the need for improved reimbursement and staff support.

4.2 Technical Working Group on Liquidity (TWGL)

Andrea Resti presented an update on the TWGL's work, which will interact with EBA workstreams on liquidity reporting formats, quantitative criteria, deposit outflows, and impact assessments. BSG members emphasized the importance of addressing macro-level issues and suggested focusing on the EBA's Regulatory Technical Standards (RTS) for liquidity. The final output will be a BSG opinion on the EBA's draft RTS, supported by empirical evidence.

4.3 Technical Working Group on Capital (TWGC)

Louise Lindgren outlined the TWGC's structure and potential focus areas, including harmonisation, capital buffers, and stress tests. The group expressed a desire to provide input before the EBA publishes certain consultation papers. The EBA supported the idea of an ad hoc meeting if feasible.

4.4 Technical Working Group on Systemic Issues (TWGSI)

Sony Kapoor introduced the TWGSI, highlighting topics such as sovereign-bank linkages, crisis mitigation, and the sustainability of EU banking models. BSG members suggested focusing on how to effectively contribute to the legislative process and addressing shadow banking remuneration and crisis management.

5. Action Points

BSG to provide its opinion on the EBA Consultation Paper on draft Guidelines for assessing the suitability of members of the management body and key function holders during the public consultation.
BSG to provide its written opinion on the EBA Consultation Paper on draft ITS on Supervisory reporting requirements for institutions (CP 50).
Robin Jarvis to establish the TWGCPI with a suitable timeline and deliverables.
Andrea Resti to coordinate the TWGL work plan with EBA mandates and organize meetings.
Louise Lindgren to establish the TWGC with a suitable timeline and deliverables.
Sony Kapoor to establish the TWGSI with a suitable timeline and deliverables.
EBA staff to seek comments from BSG members on the draft questionnaire about users/investors' needs for Pillar 3 disclosures.

6. Participants

The meeting included representatives from various sectors, including industry, consumers, SMEs, users of banking services, and top-ranking academics. Key participants included: