EBA欧洲银行-BSG-response-to-Consultation-Paper-28EBA-CP-2015-19292008-February2016_5页_225kb

EBA Banking Stakeholder Group Summary on EBA/CP/2015/19 Consultation Paper

Core Content

The EBA Banking Stakeholder Group (BSG) has provided feedback on the Consultation Paper EBA/CP/2015/19, which outlines guidelines for stress testing of deposit guarantee schemes (DGSs) under Directive 2014/49/EU (DGSD). The BSG supports the EBA's initiative to develop these guidelines, as the DGSD mandates stress testing but does not provide detailed guidance. The guidelines aim to ensure consistent and high-quality stress tests across EU Member States.

Main Views

• Support for Guidelines: The BSG supports the EBA's guidelines, which provide a comprehensive approach to stress testing. These cover key issues such as intervention scenarios and areas to be assessed, including operational and financial capabilities.
• Programme Design: It is recommended that DGSs start by designing a multi-year testing programme that includes key phases: planning, running, reporting, and corrective actions. This approach helps in learning from real-life interventions and enhances the credibility of the stress tests.
• Transitional Period Considerations: During the transitional period before the target ex-ante funding level of 0.8% of covered deposits is achieved by 2024, the results of back tests should be cautiously assessed. Funding gaps should not automatically lead to increased bank contributions, as they may be temporary.
• New Resolution Framework: The BSG emphasizes that the new resolution framework, including bail-in and resolution funds, has significantly improved the resilience of DGSs compared to the past. This should be reflected in stress tests.
• Reporting Frequency: The BSG raises concerns that reporting stress test results annually may be more demanding than necessary, as the DGSD only requires stress tests every three years.

Key Information

Specific Comments

• Objectivity in Stress Tests: The BSG supports the idea of ensuring objectivity in stress tests. They suggest that external observers could be useful, but the balance between cost and benefit should be considered. For DGSs managed by private entities, designated authorities can act as disinterested observers.
• Selection of Credit Institutions: The BSG agrees with the proposal to consult resolution authorities to identify credit institutions that may be subject to resolution, based on size and significance criteria.
• Testing SCV Files: A random sample of Single Customer View (SCV) files can be sufficient for testing, provided it is representative using standard statistical techniques.
• Assessment of THBs and Beneficiary Accounts: The BSG agrees that a qualitative assessment of arrangements for identifying temporary high balances (THBs) and beneficiary accounts is necessary, even if financial impact is difficult to forecast.
• Prioritization of Tests: They support the prioritization of payout-related operational tests and the 2019 time horizon for reporting. However, they question the comparability of the funding test calibration across DGSs.
• Cross-Border Testing: The proposed limited cross-border test is considered sufficient, but the BSG suggests that the requirement could be strengthened, especially in light of the development of guidelines on cooperation agreements.

Conclusion

The BSG generally supports the EBA's guidelines on DGS stress testing, emphasizing the importance of consistency, quality, and objectivity. They highlight the need for a balanced approach in the design and implementation of stress tests, particularly during the transitional phase of the DGSD's implementation. The group also underscores the importance of incorporating the new resolution framework into stress testing practices and calls for further clarification on the calibration and scope of cross-border tests.