EBA欧洲银行-EBA-BS-2014-392rev1-28Minutes-BoS-Telcon-14-October-201429_7页_237kb

报告摘要

EBA Board of Supervisors Teleconference Summary – EBA BS 2014 392rev1

Core Content

The EBA Board of Supervisors (BoS) convened a teleconference on 14 October 2014 to discuss three main agenda items: the final draft Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) on benchmarking, a report on remuneration and allowances, and a draft Consultation Paper on RTS on materiality thresholds for default under the Internal Ratings-Based (IRB) approach.

Agenda Item 1: Final Draft RTS and ITS on Benchmarking

Main Points

The EBA presented the final draft of the RTS and ITS on benchmarking under Article 78 of the CRDIV, finalized after a public consultation ending on 19 August 2014.
Key Changes:
- The use of quartiles was removed.
- The Standardised Approach (TSA) for market risk was eliminated, but the EBA proposed using the Basel Committee’s Group on Trading Book Issues (TBG-SIGTB) portfolios for 2015, with EBA-developed portfolios to be used from 2016 onward.
- The reference date for 2015 was proposed as 30 June (remittance date: 11 August), and for 2016 as 31 December (remittance date: 11 March).
The BoS members generally supported the work but raised concerns about:
- The use of hypothetical portfolios for credit risk potentially leading to inconsistent results.
- The legal compliance of the EBA’s proposal to share NCA assessment results.
- The proportionality principle not being adequately referenced in the RTS.
- The rotation mechanism not being sufficiently explicit.
Conclusions:
- The Commission representative would seek legal confirmation on the feasibility of the proposed measures.
- A review clause was not included in the TS, but the EBA would ensure a review process and communicate it externally.
- The TSA would be used for benchmarking purposes, not as a floor.
- Flexibility in remittance dates for credit risk was suggested for institutions facing delays.

Agenda Item 2: Report on Remuneration and Allowances

Main Points

The EBA presented a report assessing whether role-based allowances, used by some credit institutions, complied with the CRDIV rules on remuneration.
The EBA also drafted an opinion to be addressed to the European Commission and NCAs, urging the use of supervisory measures to ensure compliance.
The UK PRA had previously sent a letter to the EBA Chairperson, which was circulated to BoS members.
Some BoS members expressed concerns that the report's findings might limit the options for the remuneration guidelines.
The Chairperson clarified that the report focused on compliance, not on limiting the Guidelines, and that the EBA could not remain silent as the Guidelines would not be in force before the end of 2014.

Conclusions

The BoS adopted both the Report and the Opinion.
The report and opinion were to be forwarded to the Commission and published on the EBA website.

Agenda Item 3: Draft Consultation Paper on Materiality Thresholds for Default under IRB

Main Points

The EBA proposed a draft Consultation Paper (CP) on setting materiality thresholds for credit obligations past due to identify defaults.
The CP suggested using a combination of absolute and relative limits:
- Absolute limit: 500 EUR for non-retail, and a lower threshold for retail.
- Relative limit: A proportion of the sum of credit obligations past due by more than 90 days to the total credit obligations of an obligor.
BoS members debated:
- Whether a breach of the threshold should trigger default if either or both thresholds were breached.
- The need to differentiate between technical and real defaults to avoid misclassification and incorrect capital requirements.
- The absolute threshold for non-retail credit (500 EUR) was considered too low.
- The implementation timeframe should be extended to at least three years due to potential changes in rating systems and uncertainty in capital requirements.

Conclusions

The EBA agreed to highlight the breach criteria more prominently in the CP for further feedback during public consultation.
The implementation timeframe was left as proposed for further discussion.
A question on the quantitative impact of the thresholds was to be included in the CP.

Final Notes

A revised version of the TS and TFSB mandate was to be submitted to the BoS for approval via written procedure.
The TFSB mandate was amended to include separate teams for credit and market risk, while retaining the Taskforce’s overall oversight.
The TFSB would liaise with SCRePol and SCOP Chairs before reporting directly to the BoS.
A review clause for governance arrangements was acknowledged, with a planned review after one year.

Participants

Chairperson: Andrea Enria
Voting Members: Michael Hysek (Austria), Jo Swyngedouw (Belgium), Stoyan Manolov (Bulgaria), Damir Odak (Croatia), Argyro Procopiou (Cyprus), Zuzana Silberova (Czech Republic), Jesper Meyer (Denmark), Andres Kurgpöld (Estonia), Marja Nykänen (Finland), Philippe Richard (France), Peter Lutz (Germany), Spyros Zarkos (Greece), M. Adelaide Cavaleiro (Portugal), Adrian Cosmescu (Romania), Tatiana Dubinová (Slovakia), Jose-Luis Lopez (Spain), Uldis Cerps (Sweden), Andrew Bailey (UK)
Observers: Lilja Rut Kristófersdóttir (Iceland), Morten Baltzersen (Norway)