EBA欧洲银行-cebs6_Feedback-document_26页_195kb

报告摘要

Summary of Feedback to CEBS's Draft Guidelines for the Joint Assessment of the Elements Covered by the SREP and Joint Decision on the Capital Adequacy of Cross-Border Groups (CP 39)

Core Content

The document outlines the feedback received from eleven respondents on CEBS's draft guidelines (CP 39) aimed at structuring the joint assessment and decision process for the capital adequacy of cross-border banking groups. It also details CEBS's responses and the amendments made to the guidelines based on the feedback.

The guidelines are intended to enhance coordination among supervisory colleges and promote harmonization of supervisory practices. CEBS has taken into account the need for a clear, binding, and consistent process that involves all relevant supervisory authorities, including non-EEA entities, to avoid duplication and ensure effective oversight.

Main Points and Key Information

General Remarks

Support for Guidelines: Most respondents supported the principles and objectives of the guidelines, which aim to achieve a shared understanding of risk-based capital adequacy for cross-border banking groups.
Standardization: Some participants requested more standardization of supervisory approaches to ICAAP and SREP, as they believe this would help in reaching a joint decision in a timely manner.
Common Definitions and Templates: There was a call for common definitions, templates, scoring tables, and assessment criteria, as well as harmonized timelines and dispute resolution mechanisms.
Materiality and Proportionality: Respondents emphasized that materiality and proportionality should guide the extent of each host supervisor's involvement in the joint process.
Top-Down Approach: A more explicit "top-down" approach was suggested, with a clearer leading role for the consolidating supervisor in planning and steering the process.
Group Involvement: Stakeholders urged closer involvement of the supervised group in the joint assessment and decision process, with a focus on improving their ICAAP based on the findings.
Stress Testing Coordination: There were concerns about the potential for duplication of stress tests and the need for coordination among local, regional, and international authorities.
Non-EEA Authorities: The involvement of non-EEA supervisory authorities was welcomed, provided that confidentiality requirements are met.
EBA's Role: The future role of the European Banking Authority (EBA) in promoting the consistent application of the guidelines was acknowledged and emphasized.

CEBS's Response

Coordination and Harmonization: CEBS agrees that the guidelines represent an important step towards greater coordination and harmonization. Future changes will further align with the single rulebook and Binding Technical Standards.
Role of the Consolidating Supervisor: CEBS affirms the pivotal role of the consolidating supervisor in planning and conducting the joint assessment process, and has revised the guidelines to clarify this role.
Top-Down and Bottom-Up Components: CEBS acknowledges the need for both top-down and bottom-up components in the assessment process and has updated the guidelines accordingly.
Group Engagement: CEBS agrees that close interaction with the banking group is essential, and has included provisions for this in the guidelines, particularly in the communication of results and the discussion of findings.
Stress Testing: CEBS clarifies that the joint process should not create additional stress testing requirements, but rather enhance coordination among existing ones.
Confidentiality: CEBS assures that confidentiality provisions are in place and that information shared within the college will be handled appropriately.

Specific Comments and Revisions

The following table summarizes the specific comments and the corresponding changes made to the guidelines:

Topic, Reference	Comments Received	CEBS's Response	Amendments to the Text
Chapter 1	Make an explicit reference to GL34 and explain how they interact.	CEBS agrees and has amended the text accordingly.	Paragraph 4 has been expanded to reference GL34 and Chapter 5 thereof.
Guideline 1, Table 1.4	Finance functions should also be included in the governance analysis.	CEBS does not agree.	No changes required.
Guideline 1, Table 1.5	Highlight the weight of each risk in the entity's risk profile.	CEBS agrees.	Added sentence to paragraph 22 about highlighting key strengths and weaknesses.
Guideline 1, Table 1.5	Report the materiality of each risk, the effectiveness of the risk mitigation and the consequent residual risk.	CEBS agrees.	Added sentence to paragraph 22 about materiality of each risk.
Guideline 1, Table 2	Introduce quantitative thresholds and qualitative criteria objectively set.	CEBS agrees.	No changes required.
Guideline 3, element 1	The overall assessment would benefit from pointing out the strengths and weaknesses identified.	CEBS agrees.	Modified Table 1.1 to include analysis of strengths and weaknesses.
Guideline 3, element 1	More guidance to illustrate how materiality is considered would be welcomed.	CEBS considers this outside the scope.	No changes required.
Guideline 3, element 2, paragraph 36	The term "remuneration of the institutions return on capital" is unclear.	CEBS agrees.	Replaced with "profitability".
Guideline 3, element 2, paragraph 38	This is a sensitive confidential topic that should be handled with care.	CEBS agrees.	No changes required.
Guideline 3, element 4, paragraph 46	Supervisors should not interfere with the freedom of an institution to determine its business model.	CEBS agrees.	Reworded to clarify that supervisors should assess governance and risk management procedures.
Guideline 3, element 5, paragraph 53	Discussion of large exposures should include the national differences in approach.	CEBS agrees.	Added sentence about understanding national differences.
Guideline 3, element 5, paragraph 54	Discussion of liquidity should include the national differences in approach.	CEBS agrees.	Added sentence about understanding national differences.
Chapter 3	Insert the word "joint" in the title.	CEBS agrees.	Title of Chapter 3 has been modified to include "joint".
Guideline 5, Table 6	Risks not included in the ECM should be evaluated with a zero score.	CEBS acknowledges the concern.	No changes required.
Guideline 5, Table 6	The scoring should be accompanied by a qualitative commentary.	CEBS agrees.	No changes required.
Guideline 6, Guideline 14, Guideline 21, Guideline 23	In the event of disagreement, the consolidating supervisor should have the final word.	CEBS agrees.	No changes required.
Guideline 8	Internal capital is allocated along business rather than jurisdictional lines.	CEBS acknowledges the point.	No changes required.

Conclusion

CEBS has taken the feedback into account and made necessary amendments to the guidelines to enhance clarity, coordination, and effectiveness in the joint assessment and decision process for cross-border banking groups. The guidelines are expected to be further refined by the EBA and may serve as a basis for future Binding Technical Standards.

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