EBA欧洲银行-EBA-BSG-2015-015-28Final-minutes-0303201529_11页_245kb

EBA Banking Stakeholder Group – Summary (3 March 2015)

Core Content

The Banking Stakeholder Group (BSG) meeting on 3 March 2015 in London covered a range of topics related to regulatory developments, stress testing, capital requirements, and consumer protection. The BSG members, representing various stakeholders in the banking sector, engaged in discussions to provide input on EBA consultation papers and proposed future actions.

Main Issues and Topics Discussed

1. Welcome and Approval of the Agenda and Minutes

• The BSG Chairperson and EBA Executive Director welcomed members and approved the agenda and minutes from the previous meeting (9 December 2014).
• The Chairperson proposed to explore potential topics for a submission to the EU Institutions, including shadow banking and the ESFS review.

2. Welcome to New BSG Member

• Sabine Masuch was welcomed as the new BSG member.

3. Update on BSG Work and Stress Testing

• The BSG decided to prepare a submission on DP/2014/03 (Passport notifications) and CP/2014/46 (Resolution colleges).
• The EBA Executive Director announced that the EU-wide stress test would not be conducted in 2015 but would begin preparations for 2016 due to practical constraints.
• A new ad hoc Working Group on stress testing was proposed, with a draft to be prepared by the end of April.

4. Update on IFRS 9

• The IFRS 9 endorsement process in the EU was ongoing and expected to be completed by the end of 2015 if the draft regulation is endorsed without amendment.
• Banks had until mid-2016 to test the new regime, with the rules applicable from 2018.
• The BSG members discussed the impact of IFRS 9 on capital and stress tests.

5. Proportionality Project

• The ad hoc Working Group on proportionality planned to meet again in Brussels in late March to continue the discussion.

6. Regulatory and Oversight Developments

• The EBA Executive Director provided an update on regulatory developments, including the RCAP findings and the CVA exemptions under the CRD framework.
• The EBA also mentioned upcoming consultation papers on remuneration policies, financial contracts records, and CSDs.
• A budget cut was noted, with the EBA receiving a smaller budget than planned, affecting its work programme and data reporting infrastructure.
• The BSG expressed concerns about the budget cuts and suggested a possible response to the EU Institutions.

7. Risks and Vulnerabilities

• The EBA staff highlighted the stabilization of asset quality, subdued profitability, and an upward trend in market risk.
• Concerns were raised about financial stability and geopolitical risks in Europe, including developments in Greece and Russia.
• The BSG discussed the impact of shadow banking and low RoE on the banking sector.

8. BRRD Related Proposals

• The BSG agreed to respond to the Consultation Paper on Resolution Colleges (CP/2014/46) but not to the one on notifications and suspension (CP/2014/47).
• Concerns were raised about the role of third-country resolution authorities and the application of MREL.
• The BSG emphasized the need for proportionality and transparency in the MREL framework.

9. Capital and Risk Analysis

• The BSG Working Group discussed the EBA consultation paper on the IRB approach, highlighting issues with the separation of validation and credit control functions.
• Concerns were raised about the complexity of the revised Standardised Approach (SA) and its impact on credit institutions and consumers.

10. Consumer Protection and Financial Innovation

• The BSG discussed creditworthiness assessment and arrears/foreclosure guidelines.
• The EBA mentioned upcoming work on PSD2 and the Interchange Fee Regulation, seeking BSG input on passporting issues.
• A suggestion was made to involve consumer representatives in future discussions and to move consumer protection topics earlier in the agenda.

Key Information

• Stress Testing: The BSG will prepare a submission on stress testing and form an ad hoc Working Group by April 2015.
• IFRS 9: The endorsement of IFRS 9 is ongoing, with implementation expected from 2018.
• MREL and Resolution Colleges: The BSG emphasized the need for proportionality and transparency in the MREL framework and the structure of Resolution Colleges.
• Capital Requirements: The revised SA and capital floors were discussed, with concerns about complexity, procyclicality, and the need for country-specific factors.
• Consumer Protection: The BSG provided input on creditworthiness and arrears/foreclosure guidelines. A Consumer Day was planned for 3 June 2015 in Frankfurt.

Participants

• BSG Members: David T. Llewellyn (Chair), Andrea Resti (Vice-Chair), Sabine Masuch, and others from credit institutions, academics, consumers, and employees.
• EBA Staff: Adam Farkas (Executive Director), Mark Adams, Nicola Antoniou, and other EBA representatives.

Next Steps

• The BSG agreed to submit a paper on the IRB approach and MREL framework.
• The Working Group on proportionality planned to meet again in Brussels.
• The BSG will provide input for the upcoming Consumer Day and consider responses to the EU Institutions on the budget issue.