EBA欧洲银行-Final-Peer-review-Report-on-EBA-O-SIIs-Guidelines_79页_1mb

Final Peer Review Report Summary

Core Content

This report is the final peer review of the Guidelines on the criteria to determine the conditions of application of Article 131(3) of Directive 2013/36/EU (CRD) in relation to the assessment of other systemically important institutions (O-SILs). The review was conducted by the European Banking Authority (EBA) in November 2017, focusing on the implementation and application of the Guidelines across EU member states and EEA countries.

The review includes two phases: the self-assessment by relevant authorities (RAs), and the review by peers conducted by the EBA. The goal was to evaluate the compliance of RAs with the Guidelines, identify best practices, and provide recommendations for harmonisation.

Main Findings

Compliance with Guidelines

• The majority of RAs (28 out of 30) participated in the peer review.
• Most RAs confirmed that they fully applied the Guidelines.
• A few RAs indicated that the requirements were largely or partially applied.
• One RA did not apply the Guidelines and provided a rationale for non-compliance.
• The ECB/SSM did not participate in the self-assessment due to the national-level application of the identification process within the SSM framework.

Key Areas Assessed

1. Application of mandatory indicators for the scoring of institutions

• The peer review focused on how RAs applied mandatory indicators in their identification process.
• Figure 2 shows that most RAs applied the methodology fully or largely.
• Some RAs did not apply the methodology, while others deemed it not applicable due to market-specific reasons.

2. Setting of optional indicators

• This section of the self-assessment did not include any benchmarked questions.
• RAs were free to apply optional indicators based on their national banking sector specifics.

3. Effectiveness and comprehensiveness of disclosure and notification requirements

• The Guidelines require RAs to disclose the methodology used in the identification process.

• Figure 3 shows that most RAs fully or largely applied these disclosure requirements.

• A few RAs partially applied the requirements, and one RA deemed them not applicable.

• Notifications to the EBA were also evaluated (Question 19).

• Figure 4 indicates that most RAs fully applied the notification requirements.

• A few RAs largely or partially applied them, and one RA did not contribute.

4. Calibration of the O-SII buffer

• The calibration of the O-SII buffer was not strictly covered by the Guidelines, so no benchmarked questions were included in the self-assessment.
• The peer review highlighted the need for further guidance to reduce variation in the calibration and use of the O-SII buffer.

5. Data and decision-making processes

• RAs were assessed on their involvement of management in the identification process.
• Figure 5 shows that most RAs fully involved management.
• A few RAs considered the requirements not applicable, and one RA did not contribute.

Key Recommendations

• The Review Panel encourages the dissemination of best practices identified in the peer review (see Annex 5).
• It suggests that action should be taken in areas where harmonisation is beneficial, such as disclosure and notification requirements.
• Annex 6 summarises the Review Panel's recommendations for improving the implementation of the Guidelines.

Conclusion

• The peer review concluded that most RAs are compliant with the Guidelines.
• However, some variations in the application of the Guidelines across jurisdictions were observed.
• These variations may affect the level playing field for institutions operating in different countries.
• The Review Panel recommends further guidance to ensure consistency and harmonisation in the application of the O-SII buffer and other macroprudential tools.

Key Information

• The peer review was conducted from March to May 2017.
• It involved 27 questions covering five main areas: mandatory indicators, optional indicators, disclosure and notification, O-SII buffer calibration, and data and decision-making processes.
• 28 RAs were involved, with one RA not contributing and one RA not applying the Guidelines.
• The ECB/SSM was not involved in the self-assessment, as the identification process is managed at the national level.
• The EBA Regulation (Article 30) provided the legal basis for the peer review.
• The Review Panel used a benchmarking scale ranging from 'fully applied' to 'not applicable', to assess compliance levels.

Structure of the Report

• Annex 1 provides a list of country codes and acronyms of relevant authorities.
• Annex 2 includes the questions in the self-assessment questionnaire.
• Annex 3 offers a detailed summary of all self-assessment results.
• Annex 4 summarises the review of the self-assessment responses.
• Annex 5 outlines the best practices observed.
• Annex 6 summarises the Review Panel's recommendations.

Overall Assessment

• The peer review confirmed that the majority of RAs are compliant with the Guidelines.
• Some practices deviate from the Guidelines, indicating a need for further clarification and harmonisation.
• The EBA recommends the publication of best practices and further guidance to reduce discrepancies in the application of the O-SII buffer and other macroprudential tools.