EBA欧洲银行-BSG-2012-26-Rev1Minutes-8th-meeting-BSG-24-September-2012-_1_8页_278kb

Banking Stakeholder Group Meeting Summary - 24 September 2012

Core Content

The Banking Stakeholder Group (BSG) met on 24 September 2012 at the EBA's offices, covering a range of topics related to EU banking developments, regulatory priorities, and the role of the EBA within the Banking Union framework.

Main Agenda Items and Key Points

Agenda Item 1: Welcome and Approval of Agenda

• The meeting commenced with a welcome from the BSG Chair and the formal approval of the agenda.
• Minutes from the previous meeting were adopted.

Agenda Item 2: Developments in EU Banking

• Capital Recapitalisation: The EBA's final report on the Recapitalisation exercise was expected soon. Capital positions increased by over €200bn, with 27 banks improving by €116bn.
• Deleveraging: Concerns were largely alleviated, with no significant reduction in lending to SMEs and corporates.
• Asset Valuation: Asset quality reviews are ongoing, and the independent valuation of the Spanish banking sector was welcomed.
• Funding Models: Efforts are being made to restore stable and viable funding models, which will influence future bank business models.
• Banking Union: The EBA welcomed the EC's draft proposals, particularly the split of sovereign-bank interconnectedness. A stronger Single Rulebook and unified supervisory methodologies are emphasized.
• Segmentation and Cross-border Liquidity: Concerns were raised about the increased segmentation in the Single Market and the impact of national fiscal regimes and supervisory measures on cross-border liquidity.

Agenda Item 3: Consultation on Credit Risk Adjustments and Financial Conglomerates

• Credit Risk Adjustments (EBA CP 2012 10): BSG members emphasized the need for alignment with future IASB impairment rules and highlighted concerns about exposure values and the CRR text.
• Joint Consultation (JC CP 2012 02): Questions were raised about the transferability of capital and the prudential treatment of insurance undertakings within financial conglomerates. ESAs aim to align outcomes across different capital calculation methods.

Agenda Item 4: Regulatory Developments

• Liquidity and Leverage: EBA plans to align with Basel Committee rules and is working on data collection and report drafting.
• Crisis Management Directive: Technical standards are to be developed.
• Shadow Banking: BSG suggested collaboration with ESAs on shadow banking issues. EBA is preparing a RTS on ancillary services and their impact on shadow banking.

Agenda Item 5: EC's Recovery and Resolution Proposals

• Employee Considerations: Staff involvement in early warning systems and confidentiality constraints were raised.
• Point of Non-Viability: Clear triggers for haircuts and the "waterfall" of bail-in tools were emphasized, with concerns about legal risks and the need for clarity on bond conversion.
• Systemic Risk Buffer: Linkage with resolution frameworks and the use of buffers for contingency was discussed.
• State Aid: The EBA should assess the implications of State Aid in the context of resolution.

Agenda Item 6: Liquidity Working Group Report

• The draft report on liquidity was nearing finalization. The BSG supports the Liquidity Coverage Ratio (LCR) provided it is well calibrated.
• A disclaimer was requested if the report is published, to clarify it represents the BSG's opinion, not EBA's official stance.

Agenda Item 7: Consumer Protection Priorities

• Key consumer issues included mis-selling, responsible lending, and trust in banking services.
• The interaction between remuneration structures and financial advice was noted.
• The FSUG commissioned research on savers in private pension funds.
• EBA is monitoring consumer impact in Spain and working with ESMA on LIBOR/EURIBOR rate setting.

Agenda Item 8: Role of EBA in Banking Union

• The BSG broadly supported the Banking Union proposal but expressed concerns about the split between Eurozone and non-Eurozone countries.
• There was a call for stronger political integration before further regulatory harmonization.

Agenda Item 9: Challenges & Changes to Liquidity, Funding & Capital

• Regulatory Complexity: Interactions between regulations are complex, and Basel III may undermine risk awareness from Basel II.
• Implementation Timing: BSG requested a delay in implementation until at least 1 July 2013 to ease compliance strain.
• Derivatives and Collateral: Issues such as CVA, CCP, and margin requirements were highlighted. Implementation costs for small banks and collateral management impacts were noted.
• Simplification: Some members questioned whether regulation is becoming too complex and suggested a move towards simplicity in business models.

Agenda Item 11: EBA 2013 Work Programme

• No specific comments were provided by BSG members on the proposed work programme.

Agenda Item 12: Annual Report and BSG Coordination

• The BSG Chair suggested producing an annual report of its work, aligning with other ESA stakeholder groups.

Key Participants

• BSG Members: Representing various sectors including industry, consumers, SMEs, trade unions, and academics.
• EBA Staff: Andrea Enria (Chairperson), Adam Farkas, Corinne Kaufman, Angel Monzon, Isabelle Vaillant, Lars Overby, Stefan Andresen, Stefan Nebesky, Tea Turcaniova.

Main Viewpoints

• The BSG supports the EBA's efforts to strengthen the EU banking system, particularly through capital recapitalisation and regulatory alignment.
• Concerns were raised about cross-border liquidity issues, regulatory complexity, and the need for clarity on resolution mechanisms and capital rules.
• There was a call for greater cooperation between EBA and ECB, as well as a need for a unified supervisory approach.
• The BSG emphasized the importance of transparency and simplicity in regulatory frameworks to support sustainable banking practices.