2016年-ECB欧洲央行_ECB_contribution_to_the_European_Commissions_consultation_on_the_review_of_the_EU_macroprudential_policy_framework_19页_192kb

ECB Contribution to the Review of the EU Macroprudential Policy Framework

Core Content

The European Central Bank (ECB) has contributed to the European Commission's consultation on reviewing the EU macroprudential policy framework. The ECB emphasizes the importance of macroprudential policy as a complementary tool to monetary and microprudential policies, especially in the context of the European Monetary Union.

Main Views

• Macroprudential Policy as a Complement: The ECB highlights that macroprudential policy is essential to address systemic risks and financial imbalances, especially in a monetary union where national and sectoral disparities exist.
• Need for Institutional Review: The current framework is outdated and needs to be updated to reflect the new institutional landscape, particularly with the establishment of the Single Supervisory Mechanism (SSM) and the Capital Markets Union (CMU).
• Central Bank Role: Central banks, including the ECB, are well-suited to handle macroprudential policy due to their expertise in financial stability, independence, and the ability to act swiftly on systemic risks.
• Clarity in Responsibilities: A clear delineation of responsibilities and powers between macro- and microprudential authorities is necessary to prevent overlaps and ensure accountability.
• Enhanced Macroprudential Toolkit: The ECB advocates for expanding the macroprudential toolkit to include more targeted instruments, such as borrower-based measures (e.g., LTV, LTI, DSTI), and sectoral tools to address risks in non-banking areas like insurance and securities markets.

Key Information

Banking Union and Macroprudential Policy

• The establishment of the banking union and the development of the CMU underscore the need for a stronger and more unified macroprudential framework.
• The ECB has specific powers under the SSM Regulation, including the ability to impose higher capital requirements and to identify and address systemic risks.
• These powers must be clearly reflected in EU legal acts, and the ESRB Regulation should be revised to align with the new institutional structure.

Relationship Between Macro- and Microprudential Authorities

• The ECB supports a clear separation of responsibilities and tools between macro- and microprudential authorities.
• Pillar 2 instruments should be reserved for microprudential purposes, while explicit macroprudential instruments should be used for systemic risks.
• The CRR and CRD IV should be revised to reflect this distinction, including the removal of references to Pillar 2 in macroprudential contexts and the introduction of new articles for sectoral tools.

Macroprudential Toolkit

• The ECB proposes a single, harmonized macroprudential toolkit to be included in EU legal acts.
• This toolkit should include:
  • Borrower-based instruments (e.g., LTV, LTI, DSTI)
  • Sectoral risk weights and concentration limits
  • Leverage and liquidity requirements for non-banking entities
  • Net Stable Funding Ratio (NSFR) and Leverage Ratio (LR) as part of the macroprudential framework
• The toolkit should be regularly reviewed every three years to adapt to new risks and ensure its effectiveness.

Coordination Between Authorities

• The ECB advocates for the removal of the pecking order mechanism, which limits flexibility in the use of macroprudential instruments.
• A streamlined and simplified activation procedure is needed, with the ESRB acting as a central information hub.
• The ECB suggests that a unified activation procedure should be established for macroprudential tools in the CRR and for capital buffers in the CRD IV.

Reciprocity Arrangements

• Mandatory reciprocity should be extended to ensure cross-border consistency and reduce regulatory arbitrage.
• Exposure-based measures should be automatically reciprocated unless justified by national authorities.
• The ECB supports the application of reciprocity to measures such as real estate risk weights and countercyclical capital buffers, but opposes its use in Pillar 2.

Governance of the ESRB

• The ECB believes the ESRB should be strengthened to reflect the new institutional setup, particularly with the SSM and CMU.
• The ESRB should have a formal role in the governance of the EU, including representation from the ECB's Banking Supervision and the Single Resolution Board.
• The ECB also proposes aligning the composition of the ESRB’s Advisory Technical Committee (ATC) with the General Board.

Summary of Proposals

• Comprehensive Review: A full review of the EU macroprudential framework is necessary, focusing on coherence, effectiveness, and clarity.
• Legal Alignment: All relevant EU legal acts, including the CRR, CRD IV, and ESRB Regulation, should be updated to reflect the new institutional structure.
• Tool Allocation: Macroprudential tools should be clearly assigned to macroprudential authorities, while microprudential tools remain with microprudential authorities.
• Regular Reviews: A regular review mechanism every three years is recommended to adapt the framework to new challenges and ensure its relevance.
• Enhanced Coordination: Streamlined activation procedures and a central information hub (ESRB) are needed to improve coordination and efficiency.
• Reciprocity Expansion: Reciprocity mechanisms should be broadened to cover more macroprudential instruments and reduce regulatory arbitrage.
• ESRB Governance: The ESRB should be formally integrated into the governance structure of the EU, with increased representation and role in cross-border oversight.

These recommendations aim to strengthen the EU's macroprudential policy framework, ensuring it is effective, coherent, and adaptable to future systemic risks.