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报告摘要

Roundtable Summary: "Fostering convergence of Pillar 3 disclosures"

Core Content

On 9 December 2009, the Committee of European Banking Supervisors (CEBS) held a public roundtable to discuss the convergence of Pillar 3 disclosures and improve the comparability of related information. Approximately 50 participants, including representatives from banks, associations, and supervisory authorities, contributed to the dialogue.

The event was prompted by CEBS's findings from the June 2009 report analyzing 2008 Pillar 3 disclosures of 25 large banks against the CRD requirements. While progress had been made in the presentation of disclosures, the diversity in both content and format reduced their usefulness for market participants.

The roundtable aimed to bridge the gap between preparers (banks) and users (analysts, investors, rating agencies) of Pillar 3 disclosures, to deepen understanding of the utility and challenges associated with them.

Main Topics and Key Points

1. Usefulness of Pillar 3 Disclosures

Risk disclosures have improved, but heterogeneity and lack of user familiarity with Basel II framework limit their usefulness.
Users emphasized the need for consistency and accessibility of disclosures, especially for small banks.
CEBS reiterated the importance of easy access to Pillar 3 information.

2. Timing and Frequency Issues

Users requested that Pillar 3 information be published simultaneously with the annual report or close to it for combined analysis.
Banks acknowledged the request but raised practical concerns, particularly in the first year of implementation.
Banks also emphasized the need for disclosure frequency to be commensurate with market participants' ability to process information.
A compromise was suggested for most significant disclosures, with more frequent updates on capital and credit risk.

3. Comparability of Pillar 3 Disclosures

Comparability was a central concern, with national discretions exacerbating the issue.
Lack of common definitions and inconsistent granularity across institutions were identified as key problems.
Users called for more factual and comparable data to support Basel 2 estimates.
EBF suggested that best practices and convergence efforts could improve comparability in the medium term.
The enhancement of Pillar 3 requirements in January 2011 was seen as a balanced approach, requiring risk profile information while protecting proprietary data.

Key Presentations

Ms. Beaudemoulin (CEBS Transparency Subgroup Chair) outlined the June 2009 report findings and the bi-lateral meetings with banks.
Moody's highlighted implementation weaknesses and suggested improvements in capital structure, capital adequacy, and risk transparency.
Standard & Poor's emphasized the value of Pillar 3 disclosures but noted the need for more comparable data.
EBF discussed convergence challenges, including accounting and regulatory differences, and stressed the role of stakeholders in shaping market disclosures.
BNP Paribas addressed frequency, format, and content of disclosures, though its presentation was not available electronically.

Next Steps

In 2010, CEBS will reassess 2009 Pillar 3 disclosures.
The need for guidance will be reconsidered based on this new assessment.
CEBS plans to promote convergence by highlighting best practices.

Summary of Main Views

View	Preparers	Users
Level of Detail	Some question the detail and technicality of CRD requirements	Limited questions raised by market participants
Relationship with Financial Statements	Some prefer separate disclosures	Some view them as part of a whole
Implementation Difficulties	Mismatch with national prudential reporting	Highlighted as a challenge
Need for Guidance	Some fear additional burdens	Some welcome more specification
Frequency of Disclosure	Banks prefer less frequent updates	Users support more frequent updates on key items
Comparability	Heterogeneity and national discretion are issues	Need for common definitions and consistent granularity
Content and Format	Reluctant to provide broader perspectives	Welcome more comprehensive and structured information

Conclusion

The roundtable highlighted the importance of Pillar 3 disclosures in enhancing market transparency and discipline, but also identified key challenges such as heterogeneity, implementation difficulties, and comparability issues. The enhancement of Pillar 3 requirements in 2011 was seen as a positive step toward convergence and improved usability. CEBS is committed to further dialogue and guidance development to address these concerns.