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报告摘要

EAPB Comments on CP 10 Summary

Core Content

The European Association of Public Banks (EAPB) has provided detailed comments on the Committee of European Banking Supervisors (CEBS)'s CP 10 proposal, which outlines guidelines for the Internal Ratings-Based Approach (IRBA) and Advanced Measurement Approach (AMA). The EAPB represents 20 public banks, funding agencies, and associations across Europe, collectively representing over 100 financial institutions, EUR 3 billion in balance sheet total, and more than 180,000 employees.

Main Views

The EAPB generally supports CEBS's objective of promoting a common understanding of IRBA and AMA requirements among European supervisory authorities, aiming to facilitate cooperation under Article 129 (2) of the Capital Requirements Directive (CRD) and to converge supervisory practices in the EU. However, they express concerns about the level of detail in the proposed guidelines, arguing that:

The principle of minimum harmonization should be respected, as the Single Market's foundation is based on this principle.
National supervisory authorities should retain a reasonable range of discretion to account for national characteristics.
The guidelines should not exceed the scope of the CRD, particularly in areas where the European legislature has not adopted restrictive regulations from the Basel Framework.
The proposed standards are overly intrusive, affecting both supervisory and management functions and potentially hindering banks' ability to organize their operations effectively.

Key Concerns

Excessive regulatory burden: The detailed guidelines may increase compliance costs for banks, especially small institutions.
Overreach in scope: Some provisions go beyond the CRD and CEBS's mandate of interpreting directives.
Intrusive governance requirements: The EAPB believes certain requirements, such as detailed understanding of credit policies by the management body, are not necessary and exceed the guidelines.
Inconsistency with the principle of materiality: The requirement to apply operational risk methodologies to all areas of a bank, including non-material ones, is seen as not aligned with the materiality principle.

Specific Remarks on CP 10 Items

CP No.	Summary of Concern
No. 49	The cover letter should clearly state that the group collectively seeks authorization.
No. 153	The definition of "separately incorporated" should include more than just legal entities.
No. 154	The risk weight curve for retail exposures should be allowed in cases of temporary threshold violations.
No. 193	Tracking additional indicators for unlikeliness to pay is not necessary and could lead to competitive distortions.
No. 369	The management body should only have a general understanding of rating systems, not a detailed one.
No. 371	All persons responsible for the credit process should receive risk reports, which exceeds the guidelines.
No. 396	Risk control functions should only review rating recommendations for corporate exposures.
No. 422	The requirement for prior ex-ante authorization for ASA is not justified and should be deleted.
No. 425	The CRD only requires proof that ASA provides an improved basis for OpRisk assessment, not specific documentation of high margins or risky portfolios.
No. 429	The expectation of imposing additional requirements for Partial Use of AMA is not covered by the CRD and should be removed.
No. 430	The roll-out plan should not be based solely on the level of risk.
No. 431	Approval for AMA should apply even to individual firm roll-outs.
No. 438	The list in this section is confusing and offers no real added value.
No. 442	The reconciliation of operational risk loss data with accounting data should be rephrased to reflect a review process rather than a strict matching requirement.
No. 445	The completeness requirement should be limited to material losses.
No. 448	General data recording guidelines are sufficient for OpRisk management.
No. 460	The use of qualitative data is challenging and the proposed requirements are unclear.
No. 463	The requirement for a one-year cancellation period is not feasible under current market conditions and does not align with the CRD's 90-day residual maturity rule.
No. 464	The requirements here go beyond the CRD and should be completely reworded.

Conclusion

The EAPB emphasizes that guidelines should set targets rather than prescribe detailed steps, allowing banks to develop best practices while ensuring a level playing field. They advocate for flexibility and consistency with existing EU regulations, particularly the CRD, and suggest that some provisions should be deleted or rephrased to avoid unnecessary regulatory burden and to align with the principle of materiality.

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