EBA欧洲银行-EBA-DP-2015-02-Discussion-Paper-on-SME_58页_1mb

报告摘要

Summary of EBA Discussion Paper and Call for Evidence on SMEs and the SME Supporting Factor

Core Content

The European Banking Authority (EBA) published a Discussion Paper and Call for Evidence in July 2015 to analyze the impact of the SME Supporting Factor (SF) on small and medium-sized enterprises (SMEs) in the European Union. The SF, introduced in January 2014 under the Capital Requirements Regulation (CRR), allows credit institutions to reduce capital requirements for SME loans, aiming to improve access to credit and support the financial system during the post-crisis period.

The EBA is mandated to report to the European Commission on three key aspects:

Lending trends and conditions for SMEs
Riskiness of SMEs over a full economic cycle
Consistency of own funds requirements with SME riskiness and lending conditions

The paper also outlines the EBA's next steps, with the final report expected to be published in February 2016. It invites stakeholders to provide feedback and evidence to inform the analysis and potential policy recommendations.

Main Points and Key Information

1. SMEs in the EU Economy

SMEs constitute the vast majority of businesses in the EU, accounting for 99 out of every 100 businesses.
They represent 2 out of every 3 employees and 58 cents in every euro of value added.
Micro SMEs (less than 10 employees, turnover or balance sheet total of less than EUR 2 million) account for 92.4% of all SMEs.

2. Sources of SME Financing

Bank financing (overdrafts, loans, leasing) is the primary source of financing for SMEs.
Trade credit, grants, and subsidised bank loans are also used, but to a lesser extent.
Capital market instruments such as covered bonds and securitisation are considered alternative funding sources but are limited in outreach to SMEs.
Public support schemes exist across the EU, with institutions like the EIB Group, KFW, ICO, and CDP providing support through various mechanisms.

3. Capital Requirements and the SME Supporting Factor

The SF was introduced to reduce capital requirements for SME loans, allowing banks to increase lending.
It applies to corporate, retail, or secured by immovable property exposures, but exposures in default are excluded.
The SF is applied at a discount rate of 0.7619, reducing the risk weight for SME exposures.

4. Regulatory Treatment of SMEs

Under the Standardised Approach (SA), SMEs can be classified as either corporate or retail exposures, with retail exposures receiving a 75% risk weight.
Under the Internal Ratings-Based (IRB) approach, SMEs with turnover below EUR 50 million receive a lower asset correlation coefficient.
The SF is applied on unsecured exposures only, and secured exposures are treated separately.

5. Lending Trends and Conditions

SME bank lending declined significantly after the financial crisis, from EUR 95 billion in 2008 to EUR 54 billion in 2013/2014.
Post-crisis, while new lending to SMEs has been positive, it remains below pre-crisis levels.
Lending conditions have deteriorated, with interest rate spreads increasing from 0.89% in 2008 to 1.34% in 2009.
Charges, fees, and collateral requirements have also tightened during the post-crisis period.

6. Riskiness of SMEs

SMEs are generally riskier than larger firms, with a higher non-performing loans ratio.
They experience a more severe deterioration in key financial ratios during economic downturns.
This pro-cyclical nature of SME lending is a key concern in the analysis.

Key Questions and Call for Evidence

The EBA is seeking input on the effectiveness and impact of the SF.
Stakeholders are encouraged to provide data, evidence, and alternatives for the SF.
The call for evidence is open until 01.10.2015, and responses must be submitted via the EBA consultation page.
Responses can be disclosed or confidential, with the latter subject to review by the EBA's Board of Appeal and the European Ombudsman.

Data Considerations and Limitations

Data fragmentation and diversity in SME definitions across the EU complicate analysis.
The EBA has adopted a pragmatic approach to interpreting data due to these limitations.
Annex 4 provides an overview of SME definitions, data sources, and methodological challenges.

Regulatory Framework and Q&As

The CRR does not provide a unified definition of SME, leading to divergent interpretations across institutions.
The SME Supporting Factor is applied to unsecured exposures, and the total amount owed is a key eligibility criterion.
The EBA has compiled a set of Q&As (Annex 5) to clarify the interpretation and application of the SF.
Currency conversion and off-balance sheet exposures are also addressed in the Q&A process.

Next Steps

The EBA will use the feedback and evidence collected to prepare the final report.
The report will assess the consistency of own funds requirements with SME risk and lending conditions.
The final report is expected to be published in February 2016.

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