2016年-EBA欧洲银行管理局_END_OF_TERM_OF_OFFICE_REPORTBSG_II_33页_750kb

Summary of the BSG End of Term of Office Report

Core Content

This report outlines the activities, structure, and contributions of the second Banking Stakeholder Group (BSG2) of the European Banking Authority (EBA), covering its mandate from October 2013 to April 2016. It highlights the group's role in providing expert input to the EBA on regulatory matters, its working methods, and its impact on shaping effective and efficient banking regulation in the EU.

Main Viewpoints and Key Information

1. BSG's Role and Mission

• The BSG is a key stakeholder group that advises the EBA on regulatory matters, particularly on Regulatory Technical Standards (RTS), Implementing Technical Standards (ITS), and Guidelines.
• Its mission is to ensure that regulation is effective and efficient, and to promote a common rule book and supervisory culture across the EU.
• The BSG also supports the EBA in assessing market developments and peer reviews of competent authorities.

2. Structure and Membership

• BSG2 comprised 30 members from 13 countries, representing six constituencies:
  • 10 representatives of Credit and Investment Institutions
  • 6 independent Top-Ranking Academics
  • 4 representatives of Users of Banking Services
  • 6 Consumer representatives
  • 2 representatives of Small and Medium Enterprises (SMEs)
  • 2 Employee representatives
• Members are appointed by the EBA’s Board of Supervisors (BoS) to reflect diverse perspectives and expertise.
• The mandate of BSG2 was four years, with the possibility of renewal. The BSG suggests that future groups should have a four-year term to allow for better continuity and expertise development.

3. Working Structure and Meetings

• Three Standing Technical Working Groups (TWGs) were established to address key areas: Capital and Risk Analysis, Recovery, Resolution and Systemic Issues, and Consumer Protection and Financial Innovation.
• Ad Hoc TWGs were also formed to tackle broader issues not directly related to EBA's workflow, such as proportionality in bank regulation.
• The BSG met 13 times during its mandate, with a minimum of four annual meetings. A new rule was introduced that required members to attend at least two consecutive meetings, otherwise their position could be vacated.

4. BSG Activity and Output

• The BSG made 73 submissions in response to EBA consultation papers, focusing on RTS and ITS.
• It also provided independent opinions on various issues, such as proportionality, consumer protection, and financial innovation.
• The BSG participated in several joint meetings with the EBA’s Board of Supervisors (BoS), which were designed to foster dialogue and exchange of views on key regulatory topics.

5. Technical Working Groups' Contributions

• Capital and Risk Analysis TWG:

  • Submitted views on the Draft Guidelines for common procedures and methodologies under Article 107 (3) of Directive 2013/36/EU.
  • Highlighted the importance of maintaining the dialogue between institutions and supervisors in the Supervisory Review and Evaluation Process (SREP).
  • Emphasized the need for Pillar 2 assessments to be tailored to individual institutions and based on internal methodologies.
  • Raised concerns about the introduction of capital floors and the potential negative impact on smaller banks and IRB institutions.
  • Called for further guidance on LGD calibration, PD estimation, and back-testing procedures.

• Recovery, Resolution and Systemic Issues TWG:

  • Focused on the implementation of the Bank Recovery and Resolution Directive (BRRD).
  • Contributed to the development of level two legislation in the recovery and resolution area.
  • Highlighted the need for a balanced and harmonized approach to systemic risk management.

• Consumer Protection and Financial Innovation TWG:

  • Worked on consumer-related issues and financial innovation.
  • Supported the EBA's initiatives in organizing events and workshops focused on consumer protection and market trends.

6. Emerging Themes and Recommendations

• The BSG identified proportionality as a key theme, particularly in its report on Proportionality in Bank Regulation, which was published in December 2015.
• The report also discusses the importance of a common supervisory culture and the risks of regulatory arbitrage.
• The BSG recommends that future stakeholder groups should be given more flexibility in their structure to better reflect the diverse expertise of members.
• It also calls for a more effective use of joint meetings with the BoS, including the possibility of revising their format to enhance collaboration.
• The BSG expresses concern about the EBA's funding, especially the reduction in travel reimbursements and financial support for non-profit members, which may hinder their participation in key events.

Conclusion

The BSG has played a significant and constructive role in the EU banking regulatory process. Its work has contributed to the development of a more consistent and effective regulatory framework, while promoting a common supervisory culture. The report concludes with a set of recommendations aimed at improving the effectiveness of future stakeholder groups and enhancing the regulatory process.