2017年-EBA欧洲银行管理局_EBA_Report_on_the_functioning_of_supervisory_colleges_in_2016_63页_580kb

Summary of EBA Report: On the Functioning of Supervisory Colleges in 2016

Core Content

The European Banking Authority (EBA) conducted a comprehensive review of the functioning of supervisory colleges in 2016, focusing on supervisory cooperation, convergence, and the quality of interactions within these structures. The report outlines the EBA's monitoring approach, the progress made, and the areas requiring further improvement.

Main Conclusions and Progress Achieved

• Monitoring Approach:
  The EBA identified and classified 136 EEA cross-border banking groups and 76 active supervisory colleges into two categories:

  • Closely Monitored Colleges (20): Characterised by intense communication between EBA staff, colleges, and consolidating supervisory authorities.
  • Colleges Followed on a Thematic or Selected Basis (56): Interacted on specific topics and in selected cases.
    A new self-assessment template was introduced for the second group to capture information on joint decisions and general college processes.

• Cross-Border Banking Groups:

  • 136 EEA cross-border banking groups and 131 third-country groups were identified.
  • 68 active colleges were reported within the EEA, with 8 at the sub-consolidated level for third-country groups.
  • A total of 76 supervisory colleges were identified, with 20 classified as closely monitored.

• Supervisory Convergence Bilateral Visits:

  • Introduced in 2016 as a new tool for direct interaction between the EBA and NCAs to enhance supervisory convergence.
  • These visits helped EBA staff understand issues from both home and host perspectives, and provided hands-on advice.
  • They also facilitated discussions on topics such as materiality and coverage of subsidiaries in recovery plans.

• Organisational Aspects:

  • The EBA monitored three key organisational tasks: mapping of group entities, written coordination and cooperation arrangements (WCCAs), and supervisory examination programmes (SEPs).
  • Mapping of Group Entities: All closely monitored colleges updated their mapping templates, and the content improved significantly.
  • WCCAs: Only one college finalised its WCCA in 2016, a marked improvement from 2015.
  • SEPs: Most closely monitored colleges developed and submitted SEPs, but the preparation was often delayed, affecting the practical application of the programme.

• Level and Quality of Interaction:

  • The level and quality of interaction in supervisory colleges improved in 2016 compared to 2015.
  • 90% of closely monitored colleges exceeded the EBA's expectations in terms of interaction intensity, compared to 74% in 2015.
  • Most colleges held at least two physical meetings and quarterly conference calls.
  • The quality of discussions improved significantly, with a 'good' score achieved by all closely monitored colleges, compared to 22% 'satisfactory' in 2015.
  • The EBA maintained active interaction with 85% of colleges, showing improvement from 74% in 2015.

• Group Risk and Liquidity Risk Assessments:

  • Risk assessment reports provided a good overview of risk profiles, capturing all material risks.
  • However, business model analysis was identified as an area needing further development.
  • The process for developing and finalising risk assessment reports was generally followed, though some colleges did not complete all parts of the mandatory annexes, particularly those related to capital requirement breakdowns.

• Joint Decisions on Capital and Liquidity:

  • Joint decisions were well reasoned and referenced SREP conclusions.
  • However, the mandatory risk-by-risk decomposition of capital requirements was not shared in most colleges, leading to a missed link between risk assessments and capital requirements.
  • Liquidity joint decisions were of lower quality due to less granular reasoning and inconsistent structure, particularly for subsidiaries.

• Recovery Plans:

  • 50% of closely monitored colleges successfully completed the joint decision process on recovery plans.
  • Delays were due to challenges in handling pre-existing individual recovery plans and ensuring proper coverage of entities.
  • For some colleges, the joint decision timeline was not discussed or agreed upon, as required by the Single Supervisory Handbook (SSH).

Areas for Improvement

• Meeting Agendas:

  • In a quarter of the colleges, the agenda did not cover all relevant topics, or was not circulated for comments.
  • Topic suggestions for bank presentations were not explicitly sought from host authorities in some cases.

• Distribution of Meeting Documents:

  • 60% of colleges shared presentations only 1-3 days before meetings, which limited preparation time.
  • Some host authorities delivered only short oral updates, which did not enhance the content delivery.

• Minutes of Meetings:

  • In five colleges, minutes were not prepared for all interactions or were not shared for comments.
  • One college still had no minutes prepared, resulting in an 'improvement needed' score.

• WCCAs:

  • 45% of closely monitored colleges had not finalised their WCCAs by the end of 2016, despite starting the process in 2015.
  • Diverging views among college members led to delays.
  • Only a few colleges included information on the interaction between supervisory and resolution colleges in their WCCAs.

• SEP Preparation:

  • The preparation of SEPs was often delayed, starting only after the joint decision process rather than immediately following it.
  • This affected the timely finalisation and practical application of the SEP.
  • There was a lack of discussion on SEPs in the physical college setting, and most SEPs did not include coordinated joint work beyond legal requirements.

Key Topics for Supervisory Attention

• Risk-Related Topics:

  • Non-performing loans (NPLs) and balance sheet cleaning
  • Business model sustainability
  • Operational risk, including conduct and IT risk
  • EU-wide stress test exercise

• Policy-Related Topics:

  • Implementation of SREP guidelines
  • IRB models and cross-border cooperation
  • Impact of IFRS 9
  • Remuneration (bonus cap)

EBA Tools and Support

• The EBA provided tools to facilitate college functioning, including the IT collaboration tool and the quarterly Colleges Newsletter.
• Staff support was given in various areas, such as mapping, WCCAs, SEPs, and recovery planning.
• Training was conducted to improve college processes and interactions.

Next Steps and 2017 Action Plan

• The EBA has drawn up the 2017 Colleges Action Plan, which is included in Annex I.
• The plan outlines key tasks and topics for supervisory attention, aiming to build on the progress made in 2016 and address remaining challenges.
• The EBA continues to support colleges through bilateral visits, guidance, and training to enhance supervisory convergence and effectiveness.