EBA欧洲银行-Consultation-Paper-on-draft-EBA-Report-on-the-implementation-of-the-Guidelines-on-methods-for-calculating-contributions-to-DGSs-28EBA-2017-1029_83页_1mb

Summary of EBA Consultation Paper: Draft EBA Report on the Implementation of the EBA Guidelines on Methods for Calculating Contributions to Deposit Guarantee Schemes

Core Content

This consultation paper presents a draft EBA report assessing the implementation of the EBA Guidelines on methods for calculating contributions to deposit guarantee schemes (DGSs). The report evaluates the effectiveness of the risk-based contribution (RBC) method outlined in the Guidelines, focusing on differentiation between institutions, consistency with historical data, flexibility across Member States, transparency, reporting burden, confidentiality, and practical obstacles.

Main Objectives

The primary objectives of the report are:

• To assess whether the risk-based method ensures adequate differentiation between institutions based on their risk profile and is consistent with historical data.
• To evaluate the balance between consistent application of the Guidelines and flexibility to accommodate national specificities.
• To examine the methodology's objectivity, transparency, and the extent of additional reporting requirements.
• To identify practical issues or obstacles in the application of the current framework.

Key Findings

5.1 Adequate Differentiation and Consistency with Historical Data

• The risk-based method outlined in the Guidelines has generally met the objective of ensuring differentiation between institutions based on their risk.
• The observed differences in contributions between DGSs are consistent with the inherent risk levels in their respective sectors.
• Some DGSs have introduced methods that provide less differentiation than expected from core indicator data, indicating a degree of flexibility.
• Certain aspects of the methodology, particularly the way raw data is translated into formula components, may require revision in the future.

5.2 Balance Between Consistency and Flexibility

• There is a need for greater consistency in how riskiness is translated into the risk-based calculation formula.
• No significant evidence has been provided to justify the removal of any core indicator.
• The level of flexibility allowed by the Guidelines in the use of additional indicators does not appear to need further increase.

5.3 Objectivity, Transparency, Reporting Burden, and Confidentiality

• The methodology does not currently require excessive additional reporting.
• There is no specific need for amendments to enhance transparency for stakeholders based on current responses.
• The EBA will continue to monitor information disclosure and may consider further specifications in the future.
• Confidential information is adequately protected as per the methodology.

5.4 Practical and Potential Obstacles

• Some practical issues have been identified, such as the complexity of the model and the need for further guidance at the EU level.
• The report suggests that the current framework may not fully reflect the riskiness of all institutions.
• The EBA notes that the methodology could be simplified to improve clarity and usability.
• Recommendations for further improvements to the Guidelines will be considered as part of the broader DGSD review in 2019.

Key Information

• Deadline for implementation: 31 May 2016.

• Deadline for review: 3 July 2017.

• Guidelines issued: 28 May 2015.

• Report methodology: A mix of qualitative and quantitative analysis, using data from:

  • Approved GL RBC methods notified by Member States.
  • Covered deposits and financial means data.
  • Bank-level data submitted in anticipation of the 2017 review.
  • Survey data from DGSs.
  • Commercial data sources such as SNL.

• Calculation formula:
  $$
  C_i = CR \times ARW_i \times CD_i \times \mu
  $$
  Where:

  • $C_i$ = Annual contribution from institution 'i'.
  • $CR$ = Contribution rate (same for all institutions in a given year).
  • $ARW_i$ = Aggregate risk weight for institution 'i'.
  • $CD_i$ = Covered deposits for institution 'i'.
  • $\mu$ = Adjustment coefficient (same for all institutions in a given year).

• Risk indicators: Five core categories are specified, including capital adequacy, asset quality, liquidity, business model, and management. These indicators are used to determine individual risk scores (IRS) and aggregate risk scores (ARS), which in turn define the aggregate risk weights (ARW).

• Flexibility: Competent authorities may adjust weights or introduce additional indicators, but the total weight of core indicators must be at least 75% of the total, with no single indicator weight exceeding 15% (except for qualitative indicators from the 'Business model and management' category).

• Confidentiality and transparency: The methodology is considered objective and transparent, and it does not lead to excessive reporting requirements. Confidential information is protected as per the EBA's data protection rules.

Recommendations

• The EBA recommends that the methodology be revisited to ensure that it better reflects the riskiness of institutions.
• Further guidance at the EU level may be necessary for the development, implementation, and review of the calculation methods.
• Suggestions from DGSs and competent authorities should be considered in future revisions of the Guidelines.

Conclusion

The report concludes that the current risk-based method has largely met its objectives, but there is a need for further refinement and clarification to ensure consistency, transparency, and effectiveness. The EBA invites comments on the draft report, particularly on the methodology, flexibility, and transparency of the RBC system. Comments should be submitted by 28 August 2017, and the EBA will consider them in the context of the broader DGSD review in 2019.