EBA欧洲银行-END-OF-TERM-OF-OFFICE-REPORTBSG-II_33页_752kb

Summary of the BSG End of Term of Office Report

Core Content

This report outlines the activities, structure, and contributions of the second Banking Stakeholder Group (BSG2) of the European Banking Authority (EBA), covering its term of office from October 2013 to April 2016. It highlights the BSG's role in advising the EBA on regulatory and supervisory matters, promoting a common supervisory culture, and ensuring proportionality in regulation. The report also includes key recommendations for future stakeholder groups and an overview of the BSG's technical working groups and their outputs.

Main Points and Structure

1. Appointment and Structure

• Membership: The BSG consists of 30 members representing six different constituencies: credit and investment institutions, their employees, consumers, users of banking services, SMEs, and independent top-ranking academics.
• Term: Members serve for 2.5 years, with the possibility of renewal. The current BSG2 mandate ended on 15th April 2016.
• Structure: The BSG is composed of three Standing Technical Working Groups (TWGs): Capital and Risk Analysis, Recovery, Resolution and Systemic Issues, and Consumer Protection and Financial Innovation. Additionally, Ad Hoc TWGs were formed to address broader issues not directly linked to EBA's workflow.
• Meetings: The BSG meets at least four times a year, with a total of 13 full meetings during its term. The meetings are jointly planned by the EBA and the BSG Chair and Vice-Chair, and all members are encouraged to suggest agenda items.

2. Activity and Output

• Contributions: The BSG has made 73 submissions in response to EBA consultation papers, offering detailed and considered opinions on regulatory technical standards (RTS) and implementing technical standards (ITS).
• Independent Work: The BSG has also initiated independent studies and reports, such as the "Proportionality in Bank Regulation" report, which was not a direct response to an EBA document.
• Events Participation: Members contributed to the Joint ESAs Consumer Days, EBA Proportionality Workshops, and Research Workshops.
• Collaboration with EBA: The BSG regularly advises the EBA on the potential impact of proposed regulations, including stress tests and consumer data usage.

3. Technical Working Groups

• Capital and Risk Analysis TWG:

  • Submitted opinions on EBA's Draft Guidelines for common procedures and methodologies under Article 107(3) of Directive 2013/36/EU.
  • Addressed issues such as the integration of ICAAP and SREP, diversification, benchmarks, and the reconciliation of capital buffers with existing supervisory requirements.
  • Advocated for a careful review of the impact of the new standardised approach and capital floors, especially on smaller and larger banks.

• Recovery, Resolution and Systemic Issues TWG:

  • Focused on the implementation of the Bank Recovery and Resolution Directive (BRRD) and related regulatory developments.
  • Worked on aligning supervisory practices with the directive's objectives, including the development of common frameworks for resolution planning and systemic risk management.

• Consumer Protection and Financial Innovation TWG:

  • Addressed consumer protection, financial innovation, and the evolving landscape of banking services.
  • Contributed to the EBA's understanding of market trends and the implications of regulatory changes on consumer rights and financial stability.

• Proportionality Working Group:

  • Conducted a year-long study on proportionality in bank regulation, culminating in a detailed report.
  • Emphasized the importance of proportionality in regulatory design to avoid unnecessary burdens on institutions and to ensure regulatory effectiveness.

4. Emerging Themes

• The BSG identified a number of key themes emerging from its engagement with EBA consultation papers, including the need for a common rule book, proportionality in regulation, and the importance of a supervisory culture that avoids regulatory arbitrage.
• Concerns were raised about the complexity and accuracy of risk measurement methodologies, as well as the potential unintended consequences of overly rigid regulatory approaches.

5. Recommendations for the Future

• Mandate Length: The BSG recommends extending the mandate of future stakeholder groups to four years to allow for better continuity and learning.
• Membership Balance: There is a call for greater flexibility in the formal structure of BSG membership to ensure effective representation across all constituencies.
• Enhanced Collaboration: The BSG suggests that future meetings between BSG and the EBA's Board of Supervisors (BoS) should be more effectively utilized, possibly through a revised format.
• Proportionality Focus: Continued emphasis on proportionality in regulatory design is recommended to ensure that regulations are both effective and efficient.
• Resource Allocation: The BSG expressed concern over the EBA's budget cuts, which could hinder its ability to conduct thorough and effective work, especially given the increased regulatory demands.

Key Information

• The BSG operates independently and its outputs should not be attributed to EBA.
• The BSG's role includes advising on regulatory technical standards, guidelines, and market developments.
• The BSG has contributed to the development of a common supervisory culture and has taken initiatives beyond EBA's direct requests.
• The report includes detailed submissions on several key regulatory topics, including the IRB approach, capital floors, and proportionality in banking regulation.

Conclusion

The BSG has played a crucial role in shaping EU banking regulation, ensuring that diverse perspectives are considered in the development of supervisory standards and practices. Its work has contributed to the creation of a more coherent and proportionate regulatory framework, and its recommendations for the future aim to enhance the effectiveness and efficiency of the regulatory process.