EBA欧洲银行-2014-09-25-BSG-Opinion-EBA-CP-2014-11_5页_208kb

EBA Banking Stakeholder Group Consultation Summary on EBA/CP/2014/11

Core Content

The EBA Banking Stakeholder Group (BSG) has provided detailed comments and replies to the Consultation Paper EBA/CP/2014/11, which focuses on draft Regulatory Technical Standards (RTS) regarding the disclosure of information related to the compliance of institutions with the countercyclical capital buffer (CCB) requirements under Article 440 of Regulation (EU) No 575/2013 (CRR). The BSG supports the harmonization of supervisory rules across the EU to ensure fair competition and more efficient cross-border banking groups, while emphasizing the importance of clarity and avoiding reporting duplication.

The CCB is a macroprudential tool designed to counteract the pro-cyclicality of the financial system by requiring higher capital buffers during periods of excessive credit growth. This helps to increase the resilience of the banking system and smooth out the credit cycle. The CCB is applied to domestic exposures and is calibrated in 0.25 percentage point increments, with a minimum of zero. Each EU Member State (MS) appoints a designated authority to set the CCB rate quarterly, which applies to credit exposures within that jurisdiction. Institutions in other MSs must apply the same rate to exposures in the country setting the CCB rate, unless the rate exceeds 2.5%, in which case reciprocity is not required.

Main Views

• Clarity of Provisions: The BSG considers the draft RTS provisions to be sufficiently clear, except for some ambiguities that require further clarification.
• Disclosure Requirements: The BSG highlights the need for clarity on the level of application for disclosure templates, especially for international groups, which may need to disclose information on a consolidated, sub-consolidated, or individual basis.
• Geographical Breakdown: There is uncertainty regarding whether the breakdown of credit exposures by country applies only to European exposures or to all exposures of a group.
• Exposure Value Aggregation: The BSG is unclear on whether exposure values calculated using the Standard Approach and the Internal Ratings-Based (IRB) approach should be aggregated for the purpose of CCB disclosure.
• Implementation Costs: The BSG believes that the implementation costs are not negligible, as entities must still invest in providing detailed breakdowns of exposure values, net positions, and securitization exposures, even though some data is already required under existing regulations.

Key Information

• CCB Overview: The countercyclical capital buffer is a macroprudential tool that aims to prevent excessive credit growth and mitigate systemic risk.
• Calibration: The CCB is set in 0.25 percentage point steps, with a minimum of 0%, and is determined by the designated authority in each MS.
• Reciprocity: Reciprocity applies up to a 2.5% CCB rate. Above this threshold, it is not mandatory.
• Disclosure Scope: Institutions must disclose information on the level of application (consolidated, individual, or sub-consolidated), the geographical distribution of credit exposures, and the exposure value of credit, trading book, and securitization exposures.
• Clarification Needed: The BSG calls for clarification on the scope of disclosure templates, the geographical breakdown, and the aggregation of exposure values to avoid ambiguity and ensure consistency across institutions and supervisory authorities.

Recommendations

The BSG urges the EBA to address the identified ambiguities and uncertainties in the draft RTS to ensure effective implementation and alignment with the objectives of macroprudential supervision. The group emphasizes the importance of clarity in the disclosure requirements to enhance market discipline and support the stability of the EU financial system.