EBA欧洲银行-MBNA_3页_199kb

MBNA Europe Bank Limited Response to CEBS Consultation Paper CP03

Core Content

MBNA Europe Bank Limited, a subsidiary of MBNA America Bank, N.A., which is itself a principal subsidiary of MBNA Corporation, has submitted an initial response to the Committee of European Banking Supervisors (CEBS) Consultation Paper on the Application of the Supervisory Review Process under Pillar 2 of the New Basel Capital Accord (New Accord). The letter outlines MBNA's views on the implementation of the revised supervisory framework and emphasizes the need for consistency and cooperation between home and host regulators.

Main Points and Key Information

1. Introduction and Support for Uniformity

• MBNA supports the need for a uniform application of the New Accord across supervisory boundaries.
• The letter highlights that international institutions, including those in the U.S. and U.K., face shared challenges with home/host supervisory responsibilities.
• MBNA welcomes the Consultation Paper CP03 and agrees in principle with the proposals, particularly those related to supervisory cooperation.
• However, there is a concern that the lack of support for the lead supervisor role, as expressed in a recent speech by Mr. Roldan, contradicts the broader need for cooperation with U.S. regulators, such as the Office of Comptroller of the Currency (OCC).

2. Supervisory Review Process (SREP)

• MBNA supports the four principles of the supervisory review process agreed by the Basel Committee.
• They agree that dialogue and feedback between supervisors and firms are essential for the success of SREP and ICAAP processes.
• A concern is raised that without clear guidance on the 'lead supervisor' role, firms may be required to prepare multiple SREPs, leading to duplication of effort.
• MBNA advocates for a level playing field in the EU and requests CEBS to develop global relationships with other regulatory bodies.

3. ICAAP (Internal Capital Adequacy Assessment Process)

• MBNA supports the need for a comprehensive ICAAP that reflects the risks posed by business activities and the operating environment.
• They stress the importance of consistency between home and host regulators to avoid duplication in ICAAP development and SREP performance.
• Agreement is needed between regulators on the firm's definition of economic cycles and stress test scenarios.

4. ICAAP High Level Principles

• MBNA supports the high-level principles for ICAAP, particularly the integration of Basel II risk management measures into day-to-day bank operations.
• They seek further clarification on whether the principles imply a resource-intensive mechanical solution or a more integrated approach.
• MBNA accepts the definitions of Risk and Control factors.

5. SREP High Level Principles

• MBNA agrees with and supports the high-level principles of the Supervisory Review Evaluation Process (SREP).

Conclusion

MBNA Europe emphasizes the importance of a consistent and cooperative approach to the implementation of the New Accord across both European and U.S. regulatory environments. They advocate for clarity on the 'lead supervisor' role and the alignment of supervisory expectations to reduce redundancy and enhance the effectiveness of the regulatory framework.