EBA欧洲银行-BSG-response-to-Consultation-Paper-28EBA-CP-2015-17292021-January-2016_6页_239kb

EBA Banking Stakeholder Group Summary on Consultation Paper EBA/CP/2015/17

Core Content

The EBA Banking Stakeholder Group (BSG) has provided detailed comments on the Draft Guidelines on Communication Between Competent Authorities Supervising Credit Institutions and Statutory Auditors and Audit Firms. These guidelines aim to improve the exchange of information between supervisory bodies and auditors, with the objective of enhancing the quality of audit reports and supervisory effectiveness.

Main Viewpoints

• Enhanced Information Sharing: The BSG supports the idea of improved communication between competent authorities and auditors, believing it will lead to more accurate and relevant audit reports (Basel Pillar III) and more timely and verified supervisory information (Basel Pillar II).

• Reinforcement of Responsibilities: The communication framework should not weaken the responsibilities of either competent authorities or auditors. It should instead support and complement their roles through effective cooperation.

• Harmonization Across Member States: The BSG emphasizes the need for harmonization of practices, particularly for G-SIIs (Group Systemically Important Institutions) and O-SIIs (Other Systemically Important Institutions), as the ECB has supervisory responsibilities over these entities.

• Proportionality Principle: The BSG acknowledges the importance of a proportionality approach, which allows for tailored communication depending on the size and complexity of the institution.

Key Information

Scope of Application

• The scope is considered sufficiently clear.
• The BSG suggests that the guidelines should also cover statutory auditors of subsidiaries when they differ from the group statutory auditor, ensuring both are treated as a single entity in communication.

Application Date

• The BSG believes the application date in the last quarter of 2016 is appropriate, as it allows for preparation of audit schedules.
• They encourage the EBA to approve and deliver the guidelines as soon as possible.

Communication Framework

• The guidelines distinguish between standard communication for non-systemically significant institutions and in-depth communication for G-SIIs, O-SIIs, and troubled institutions.
• The BSG notes that the framework for in-depth communication is well-defined, but the actions for non-systemically significant institutions remain at the discretion of the competent authorities.

Scope of Information

• The BSG broadly agrees with the scope of information to be shared.
• They recommend including issues related to corporate governance statements and internal control and risk management systems in the list of topics for communication, as outlined in Article 20 of the Accounting Directive 2013/34/EU.

Form of Communication

• The BSG believes that physical meetings are the most effective form of communication for most credit institutions, not just for in-depth cases.
• They suggest that the guidelines should prioritize physical meetings and only use written communication in specific cases.

Participants in Communication

• The BSG supports the current list of participants.
• They recommend including the audit committee as a third party in trilateral communications, given its role in internal control and its relationship with auditors.
• The audit committee should have full access to all communication-related information.

Frequency and Timing

• The BSG recommends that communication occur at least twice: once at the beginning of the audit process and once at the conclusion.
• Early communication is crucial for auditors to revise their audit planning, and final communication should happen before the audit report is signed.

Collective Communication

• The BSG agrees that the guidelines should include main concerns of competent authorities and guidance on new issues in Annex I.
• They also suggest including problems encountered in past audits and possible solutions.

Impact Assessment

• The BSG agrees with the impact assessment and its conclusions.
• They highlight the benefits of the communication framework, including improved financial reporting quality and supervisory effectiveness, which outweigh the additional costs.

Conclusion

The BSG endorses the overall approach of the draft guidelines and believes that effective communication between competent authorities and statutory auditors is essential for the stability and transparency of the financial system. They advocate for the early and regular exchange of information, the inclusion of corporate governance elements, and the consideration of the audit committee in trilateral communications. The proposed guidelines are seen as a valuable tool for enhancing the oversight of credit institutions.