2014年-EBA欧洲银行管理局_Peer-Review-Report-on-the-functioning-of-colleges_28页_247kb

CEBS Peer Review on the Functioning of Supervisory Colleges (2010)

Core Content

The CEBS Review Panel conducted a peer review of the functioning of supervisory colleges in the European Economic Area (EEA) between April and June 2010, with the aim of encouraging supervisory convergence and improving the effectiveness of multilateral cooperation in the supervision of cross-border banking groups. The review was based on a sample of 17 supervisory colleges, all of which were operational at the time of the assessment.

Main Objectives

• To evaluate the implementation of supervisory provisions outlined in Community legislation, CEBS guidelines, and other relevant documents.
• To identify good practices and areas for improvement in the functioning of supervisory colleges.
• To support the development of a more unified and efficient supervisory approach across the EEA.

Key Reference Documents

• Articles 129 (1), 131 (1 & 2), and 132 of Directive 2006/48/EC
• CEBS-CEIOPS 10 Common Principles for Colleges of Supervisors
• CEBS Template for the Multilateral Cooperation and Coordination Agreement for the supervision of the XY Group (2009 version)
• CEBS Guidelines for cooperation between consolidating supervisors and host supervisors (GL09)

Methodology

• The peer review followed a structured methodology, including:
  • A self-assessment phase conducted by national supervisors.
  • A review phase where the Review Panel evaluated the self-assessments and identified good practices.
• The self-assessment questionnaire was divided into two parts:
  • Part I: Background information for all supervisors in the SON banking groups.
  • Part II: Functioning of the colleges, completed only by members of the colleges.
• The Review Panel focused on three core areas: Information Exchange, Risk Assessment, and Planning and Coordination.
• Essential and important criteria were used to assess the implementation of the reference documents.
• Additional criteria captured advanced practices useful for further CEBS development.

Main Findings

1. Information Exchange

• A majority of colleges applied the requirements for information exchange.
• Variety in the interactivity, frequency, timeliness, scope, and means of exchange was observed.
• Good practices included the use of web platforms, conference calls, and quarterly newsletters.
• Bilateral contacts were common, but multilateral exchange was still needed for effective coordination.
• Only one college discussed the distinction between essential and relevant information as per the CRD.
• Recommendations:
  • Develop a non-exhaustive list of shared information to improve structure.
  • Promote regular and timely multilateral information exchange.

2. Risk Assessment

• Variations in risk assessment processes were noted.
• Some colleges used a top-down approach, while others used a bottom-up, more interactive method.
• A common template and scoring scale were used by approximately one-third of the colleges, indicating anticipation of the JRAD guidelines.
• Good practices included:
  • Risk expert meetings or workshops.
  • Joint inspections on specific risks and ICAAP.
  • Use of CEBS sectoral risk assessment, stress tests, and liquidity identity cards.
• Results:
  • 15 colleges fully applied the risk assessment requirements.
  • 2 colleges (National Bank of Greece and RBS) did not apply them satisfactorily.

3. Planning and Coordination

• Planning and coordination were identified as a challenging task for many consolidating supervisors.
• Common supervisory planning was still underdeveloped, though joint inspections were widespread.
• Good practices included:
  • Regular updates of supervisory plans.
  • Joint on-site inspections, which provided benefits such as:
    • Joint understanding of group activities and risks.
    • Better knowledge of local markets.
    • Improved challenge to group management.
    • Avoidance of duplication of work.
    • Facilitation of follow-up activities.
• Results:
  • 9 colleges fully applied the planning and coordination requirements.
  • 3 colleges partially applied them.
  • 5 colleges did not apply them satisfactorily.

Conclusions

• The functioning of supervisory colleges is an evolutionary process, and it is a joint responsibility of all members, led by the consolidating supervisor.
• Although progress has been made, there is still room for improvement in terms of:
  • Common frameworks for information exchange.
  • Joint risk assessment methodologies.
  • Coordinated planning and follow-up activities.
• The Review Panel emphasized the added value of being part of a supervisory college, as noted by one supervisor: “To be part of a supervisory college brings added value to your own work.”
• The report aims to contribute to the convergence of supervisory practices in the EU and to support the development of more effective and coordinated supervision.

Key Takeaways

• Multilateral cooperation is essential for effective supervision.
• Standardization and common frameworks are needed to improve convergence.
• Joint inspections and interactive communication are seen as good practices.
• The JRAD guidelines are anticipated to further improve the functioning of colleges.
• Supervisory colleges are not yet decision-making bodies, but they play a crucial role in shaping a more collective supervisory approach.