EBA欧洲银行-Intesa-Sanpaolo_CP39_4页_112kb

Intesa Sanpaolo Response to CEBS Consultation Paper on Joint Assessment Guidelines

Core Content

Intesa Sanpaolo, one of the largest European banking groups and a leading bank in the Italian market with a strong international presence in Central and Eastern Europe and the Mediterranean, has provided feedback on the CEBS consultation paper regarding the joint assessment of the supervisory review and evaluation process (SREP) and the capital adequacy of cross-border groups (CP 39). The response highlights the importance of harmonizing supervisory approaches across the EU and emphasizes the need for a structured, coordinated, and efficient joint assessment process.

Main Views and Key Points

General Comments

• Common Approach: Intesa Sanpaolo supports the development of a common approach for joint assessment under Pillar 2, which should include common templates, methodologies, criteria, harmonized timelines, and clear dispute resolution mechanisms.
• Role of Consolidating Supervisor: The consolidating supervisor plays a pivotal role in ensuring the proportionality principle is applied throughout the assessment process and reflected in the final evaluation.
• ICAAP Evaluation: The Group believes that the ICAAP (Internal Capital Adequacy Assessment Process) should be evaluated as a consolidated process, rather than simply as the sum of individual assessments, to avoid inconsistencies in the analysis perimeter.
• Dialogue and Communication: Constant communication with the supervised institution, particularly the parent company, is essential for an accurate assessment of the group's capital adequacy and risk management.

Temporal Dimension

• Harmonized Timelines: The Group suggests aligning the deadlines for ICAAP submissions across national processes to reduce administrative burden and duplication. This should be synchronized with the business cycle, such as budgeting and planning processes.

Proposed Revisions

• Intermediate Step: The guidelines should be presented as an intermediate step toward a fully harmonized supervisory framework in the EU.
• Reference to GL 34: A clear reference to the CEBS Guidelines for the operational functioning of supervisory colleges (GL 34) should be included, particularly how it interacts with the proposed guidelines.
• Joint Assessment at All Levels: The title of Chapter 3 should include the word "joint" to reflect the intention of a group-wide and individual entity assessment.
• Structured Dialogue: The methodology should require a coherent and coordinated time-plan for both local and consolidated ICAAP processes to avoid duplication.
• Parent Company Involvement: The dialogue with the parent company should be explicitly mentioned in the assessment process, especially for evaluating centralized functions like risk management and governance.

Compliance with Minimum Requirements

• Consolidated Supervisor's Role: The lead role of the consolidated supervisor should be clearly underlined in the assessment of compliance with minimum requirements set out in the CRD (Capital Requirements Directive).

Determination of Own Funds

• Regulatory Capital Clarification: The Group believes that the reference to "original own funds (Tier 1 capital)" in §122 is confusing and may restrict the application of Article 136.2 of the CRD. They suggest replacing it with "regulatory capital" to avoid limiting the supervisor's discretion.
• Joint Decision at All Levels: Guideline 23 should be reworded to include the possibility of a joint decision at both consolidated and individual entity levels, in line with the consultation paper's goal of promoting joint assessments.

Key Information

• Intesa Sanpaolo advocates for a unified supervisory approach across the EU to enhance cooperation and efficiency.
• The consolidating supervisor is central to ensuring proportionality and a holistic view of the group's capital and risk management.
• The Group emphasizes the need for a common language, clear definitions, and structured dialogue in the joint assessment process.
• They propose harmonizing timelines and aligning the ICAAP processes with the business cycle to reduce administrative burden.
• There is a call for legislative clarity on capital add-ons and for a common definition of diversification benefits across the group.

Conclusion

Intesa Sanpaolo's response underscores the importance of a coordinated, harmonized, and transparent supervisory framework for cross-border banking groups. The Group supports the development of joint assessment methodologies that ensure consistency, efficiency, and a comprehensive view of the group's capital adequacy and risk management practices.