EBA欧洲银行-CP34_Unicredit_6页_173kb

报告摘要

UniCredit Group Summary on CEBS CP 34: Operational Functioning of Colleges of Supervisors

Core Content Overview

UniCredit Group has provided detailed feedback on the CEBS CP 34 document, which outlines the operational functioning of Colleges of Supervisors (CoS) in cross-border banking groups. The group emphasizes the importance of consolidated supervision and the role of the European Banking Authority (EBA) and the parent company in this process.

Main Points and Key Information

1. Role of the Consolidating Supervisor and EBA

Role of the Consolidating Supervisor: The consolidating supervisor is central to the CoS, responsible for setting up the group's entity mapping, defining the CoS structure (core and general), coordinating meetings, and facilitating cooperation.
EBA's Role: UniCredit Group believes that the EBA should be more actively involved in promoting a level playing field across the CoS, particularly in normal and stress conditions. The current role of CEBS/EBA is considered marginal, which limits its effectiveness in driving convergence and enforcement.
Parent Company's Role: The parent company is viewed as the primary tool for managing crises due to its access to information, knowledge, and understanding of the group's business model.

2. Governance of the CoS

Chairing and Agenda Setting: The consolidating supervisor should chair the CoS and set the agenda and action plans.
Frequent Meetings: The group suggests that the CoS should meet more frequently than once a year to foster convergence and joint decision-making.
Supervisory Teams: The formation of supervisory teams is welcomed, and the participation of experts from the supervised entity is encouraged.

3. Information Sharing and Communication

Coordinated Communication: The consolidating supervisor should coordinate communication with the supervised group and ensure that local supervisors inform the group about their activities.
Single Entry Point: The parent company is proposed as a single entry point for communication and requests from the CoS, which enhances efficiency and clarity.

4. Voluntary Sharing and Delegation of Tasks

Specialisation and Efficiency: Specialisation among supervisors is seen as beneficial for more efficient supervision.
Need for Incentives: There is a lack of mechanisms to incentivize the sharing and delegation of tasks, which could hinder the effectiveness of the CoS.
Supervised Entity's Role: The supervised entity should be informed about the sharing and delegation of tasks to ensure transparency and alignment.

5. Joint Decision-Making

Model Validation and Risk-Based Capital: The CoS should lead the process of model validation and risk-based capital adequacy assessment. However, there are concerns about the lack of mechanisms to ensure joint decisions without voluntary cooperation.
Consistency in Assessments: A standardized template for assessments is crucial to ensure consistency and facilitate comparison across supervisors.

6. Macro-Prudential Risks

Macro-Prudential Assessment: The CoS should assess macroeconomic and financial developments that may impact the group, as well as identify systemic risks.
Clarification Needed: The cooperation with the European Systemic Risk Board (ESRB) in this area requires further elaboration.

7. Emergency Situations

Contingency Planning: Core members should prepare contingency plans in cooperation with central banks and finance ministers.
Coordinated Response: The consolidating supervisor is responsible for collecting information and coordinating the supervisory response, but the role of CEBS/EBA is not clearly defined.
Communication: Clear and coordinated communication during emergencies is essential, but the current framework lacks incentives and conditions to ensure this.

Conclusion

UniCredit Group acknowledges the increased focus on consolidated supervision but expresses concerns about the limited role of CEBS/EBA in promoting convergence and enforcing a level playing field. The CoS is seen as a platform for information exchange and facilitation rather than an active decision-making body. During emergencies, the CoS's effectiveness is questionable due to the lack of structured mechanisms and the absence of CEBS/EBA involvement. The group supports the idea of a more integrated and structured approach to CoS operations, particularly in terms of governance, communication, and joint decision-making.

Contact Persons

Area Heads

Gabriele Stinco, Strategic Risk Management And Control, SRMC: gabriele.stinco@unicreditgroup.eu
Sergio Lugaresi, Regulatory Affairs, RA: sergio.lugaresi@unicreditgroup.eu
Guido Moscon, Banking Supervisory Relations: guido.moscon@unicreditgroup.eu