EBA欧洲银行-ZKA_CP05_4页_371kb

CEBS Consultation Paper Summary: Common European Framework for Supervisory Disclosure

Core Content

The CEBS consultation paper outlines a proposed common European framework for supervisory disclosure, aimed at enhancing transparency and accountability in the EU banking sector. The framework is designed to support the effective implementation of Basel II across the EU by providing a standardized approach to disclosing supervisory rules and practices. The paper emphasizes the importance of a consistent and comprehensive disclosure system that not only includes the rules themselves but also their interpretation and application by national supervisors.

Main Views and Key Recommendations

• Transparency and Accountability: CEBS's framework is seen as a significant step towards achieving transparency in supervisory practices. It is believed that such transparency will help in aligning European supervisory standards and promoting the internal market.

• Principle of No Additional Data Collection: A key principle of the framework is that institutions are not required to collect additional data beyond what is already mandated. This reduces the compliance burden on banks while still providing valuable information to supervisors and the public.

• Need for National Interpretation Disclosure: The ZKA (Zentraler Kreditausschuss) argues that national supervisory interpretations and applications are critical to achieving full transparency. They recommend that CEBS include these in the disclosure requirements, especially in areas such as partial use, use test, and conditions for admission of IRB approaches.

• Language of Disclosure: The ZKA strongly opposes the idea of disclosing information only in English, as it limits the accessibility and usefulness of the data for non-English speaking banks and supervisors. They advocate for all documents to be made available in English to ensure broader understanding and practical benefit.

• Frequency of Updates: The current requirement for annual updates of disclosures is considered insufficient. The ZKA suggests that changes should be published immediately upon occurrence, with the possibility of email alerts for specific disclosure elements.

• Data Accessibility and Format: To improve usability, the ZKA recommends that data be made available in formats such as Excel, which would facilitate easier processing and integration into internal systems of banks.

• Confidentiality Waiver Reporting: There is a suggestion that CEBS members should report all instances where they use the confidentiality waiver to prevent disclosure. This would help ensure responsible use and maintain transparency regarding the reasons for non-disclosure.

• International Expansion: The ZKA recommends that CEBS compare EU supervisory rules with those of non-EU countries and consider expanding the initiative internationally, starting with major Basel Committee member countries like the USA, Japan, and Australia.

Detailed Comments

• Data Maintenance and Linkage: The success of the web-based disclosure system relies on the regular and careful updating of data. Cross-references and links between national supervisory pages and the CEBS site must function smoothly, with clear responsibility assigned within CEBS.

• Alert System for Updates: An email alert system for updates is suggested to keep the industry informed. This system should allow subscribers to specify which elements of disclosure they wish to be alerted about, to reduce unnecessary notifications.

• Standardization of Data Formats: The ZKA recommends that data tables be made available in Excel or similar formats to ease data processing for banks.

• Clarification of Supervisory Discretion: Paragraphs 25 iii and 99 are welcomed for their emphasis on confidentiality, but the ZKA suggests that supervisors should clarify which national options and discretions are available to institutions to avoid ambiguity.

• Disclosure of Basel I Data: Where available, Basel I data should be disclosed alongside Basel II data to facilitate comparative analysis.

Conclusion

The ZKA supports the CEBS initiative to establish a common European framework for supervisory disclosure but emphasizes the need for greater clarity, consistency, and accessibility. They call for the inclusion of national interpretations, immediate updates, and multilingual availability to ensure the framework is both effective and widely applicable. Additionally, they suggest extending the initiative to non-EU countries to enhance international transparency and cooperation.