EBA欧洲银行-BSG-2013-Final-Report_25页_578kb

End of Term of Office Report of the Banking Stakeholder Group (BSG) of the EBA Summary

Core Content

The End of Term of Office Report outlines the activities and contributions of the Banking Stakeholder Group (BSG) of the European Banking Authority (EBA) during its first term of office, from March 2011 to September 2013. The BSG was established to facilitate stakeholder input into the EBA's regulatory process, ensuring a balanced and representative perspective from various banking sectors and related interests.

Main Tasks and Objectives

The BSG was tasked with:

• Advising the EBA on regulatory and implementing technical standards (RTS and ITS) related to bank capital, liquidity, consumer protection, and systemic issues.
• Contributing to the development of a common supervisory culture across the EU.
• Supporting peer reviews and market developments analysis.
• Providing opinions on issues beyond the EBA's direct regulatory proposals, including strategic considerations such as the Single Supervisory Mechanism (SSM) and the European Banking Union.

The BSG's mission was to ensure effective and efficient regulation that supports the key role of banks in the economy, while avoiding regulatory arbitrage.

Key Views and Contributions

• The BSG played a crucial role in shaping regulatory standards, especially in capital and liquidity areas, due to the ongoing banking crisis and regulatory reforms.

• It actively participated in the EBA's work, including the preparation of consultation papers, draft technical standards, and guidelines.

• The BSG published detailed opinions on various EBA documents, including:

  • Draft Regulatory Technical Standards (RTS) on Own Funds
  • Draft Implementing Technical Standards (ITS) on Disclosure for Own Funds
  • Draft ITS on Supervisory Reporting Requirements for Leverage Ratio
  • Draft RTS on Capital Requirements for Central Counterparties (CCPs)
  • Draft Technical Standards on Credit Risk Adjustments
  • Draft RTS on Materiality of Extensions and Changes of Internal Approaches
  • Data Point Models for Leverage Ratio and Liquidity Coverage
  • Draft ITS on Additional Liquidity Monitoring Metrics
  • Draft RTS on Additional Liquidity Outflows

• The BSG also provided opinions on:

  • The Joint Committee's proposals on FICOD
  • The EBA's Report on Consumer Trends 2012
  • Good Practices for ETF Risk Management
  • Product Oversight and Governance Processes (as per SCConFin)
  • Foreign Currency Lending (as per ESRB)

• A Position Paper on Liquidity was issued in October 2012, aiming to influence future liquidity regulation rather than merely responding to existing EBA proposals.

Structure and Membership

The BSG consisted of 30 members representing the following six constituencies:

• Credit and Investment Institutions
• Employees' Representatives
• Consumers
• Users of Banking Services
• Small and Medium Enterprises (SMEs)
• Independent Top-Ranking Academics

Each member served in a personal capacity, not as representatives of their organizations.

Membership Distribution

• 10 representatives from Credit and Investment Institutions (including 4 from cooperative and savings banks)
• 6 Independent Top-Ranking Academics
• 5 Users of Banking Services
• 5 Consumer representatives
• 3 SME representatives
• 1 Employees' representative

The Chairperson was Sony Kapoor, and David T. Llewellyn was the Vice-Chairperson. After Kapoor stepped down, David T. Llewellyn became the new Chairperson and Christian Lajoie the new Vice-Chairperson.

Working Methods

• The BSG met at least four times per year, with the possibility of more frequent meetings.
• Members who missed two consecutive meetings could be replaced by the BoS.
• The BSG established four Technical Working Groups to focus on specific areas:
  • Bank Capital (Coordinator: Louise Lindgren)
  • Bank Liquidity (Coordinator: Andrea Resti)
  • Consumer Protection (Coordinator: Robin Jarvis)
  • Systemic Issues (Coordinator: Sony Kapoor)

These groups operated through email and conference calls, with plenary discussions on major outputs. They contributed to the drafting of responses to EBA consultations and influenced regulatory thinking on key issues.

Collaboration and Engagement

• The BSG had joint meetings with the EBA's Board of Supervisors (BoS), which were jointly chaired by the BSG and EBA Chairpersons.

• These meetings included discussions on:

  • Market developments
  • Bank liquidity requirements
  • Consumer protection
  • SSM and Banking Union
  • Recovery and Resolution regime
  • The review of the European System of Financial Supervision (ESFS)

• The BSG also contributed to regulatory events such as:

  • EBA's Consumer Day (2012)
  • EBA's Research Workshop (2012)
  • Joint ESAs Consumer Day (2013)

Assessment and Recommendations

The BSG concluded that it worked effectively during its term, but suggested several improvements for future efficiency:

• The EBA should consult the BSG earlier in the regulatory process, ideally before issuing consultation papers.
• More explicit feedback from the EBA on BSG opinions would enhance interaction and collaboration.
• The resources allocated to the BSG and its Technical Working Groups could be enhanced to support more independent research and non-scheduled meetings.
• Greater access to EBA's internal data (e.g., Pillar 3 data) would improve the quality and relevance of the BSG's input.

Conclusion

The BSG played a vital role in the regulatory process of the EBA, contributing expertise, perspectives, and strategic insights. Its collaborative approach and diverse membership helped in shaping sound regulatory frameworks. The report also expressed appreciation for the support from EBA staff and key collaborators, and acknowledged the dedication of all BSG members.

The BSG's work laid a foundation for future regulatory efforts and highlighted the importance of stakeholder engagement in the European Banking Union and single rulebook development.