EBA欧洲银行-CP34_ING_4页_103kb

ING Group N.V. Summary of Response to CEBS Guidelines for the Operational Functioning of Colleges (CP34)

Introduction

ING supports the CEBS guidelines on the operational functioning of supervisory colleges, believing that such structures can enhance cooperation between supervisors and supervised entities, particularly in cross-border and cross-sectoral groups. The guidelines are seen as a step toward more efficient and effective supervision, both in normal operations and during financial distress. While information sharing is acknowledged as a crucial first step, ING emphasizes the need for more intensive coordination and a unified approach to supervision.

Core Content

• Commitment to Supervisory Colleges: ING views supervisory colleges as essential for improving mutual understanding and cooperation among supervisors.
• Global Perspective: ING believes that colleges should be global for global firms and not separated into EU and international colleges, advocating for integration in decision-making and mediation.
• Confidentiality and Information Sharing: ING supports the establishment of procedures to protect confidential corporate and client data, while also advocating for clearer mechanisms to aggregate data for macro-systemic purposes.
• Harmonization of Supervision: ING stresses the importance of a harmonized legislative foundation for colleges, noting that the current CRD (Capital Requirements Directive) has national discretions that hinder this goal.
• Consolidated Supervision: ING supports consolidated supervision for cross-border financial groups and highlights the need to move away from fragmented, local approaches that may reduce efficiency.
• Coordination of Requests: ING believes that information requests should be coordinated within the college to avoid inconsistencies and inefficiencies.

Main Views

• Voluntary Sharing and Task Delegation: ING sees these as efficient tools for leveraging expertise and capacity, but notes that they may be less likely to occur in groups with centralized risk and capital management.
• Model Validation and Risk-Based Capital Adequacy: ING highlights the need for a unified approach to model validation and risk-based capital adequacy, as current practices often result in divergent requirements and capital expectations across local entities.
• Stress Testing: ING advocates for coordination of stress testing within the college to ensure a coherent view of the group's robustness.
• Going Concern and Emergency Situations: ING supports the guidelines for planning and coordination in going concern situations but believes that the consolidated supervisor should have the authority to determine action plans, rather than local authorities.
• Macro Prudential Risks: ING emphasizes the importance of coordinated approaches to macro prudential risks, especially in times of distress, to prevent nationalistic approaches that may affect all stakeholders.

Key Information

• Operational Organization: Colleges must be global, and integration between European and international colleges is necessary.
• Information Exchange: ING supports the coordination of information requests and the harmonization of legislative approaches.
• Pillar 2 Process: ING is an IRB bank but has subsidiaries on the Standardised approach. It uses internal models for the entire banking book under Pillar 2.
• Binding Mediation: ING supports the introduction of a binding mediation mechanism in the EU, even though it may be seen as a challenge to national sovereignty. They argue that without such a mechanism, the college model cannot be fully effective.

Conclusion

ING believes that the college model can significantly enhance the effectiveness of financial supervision, especially for global institutions. They advocate for a more integrated, harmonized, and coordinated approach across both European and international levels, with a clear structure for decision-making and mediation. ING also emphasizes the need for a binding mediation mechanism to ensure accountability and final recourse in cases where consensus cannot be reached.