EBA欧洲银行-2014-09-09-EBA-SREP-Guidelines-for-Public-Hearing_22页_1mb

报告摘要

Summary of the EBA Common SREP Framework Guidelines

Core Content

The European Banking Authority (EBA) introduced Guidelines for Common Supervisory Review and Evaluation Process (SREP) in 2014, aimed at enhancing consistency and quality of supervision across the European Union. These guidelines are a key component of the Single Rulebook, focusing on supervisory practices for both Single Supervisory Mechanism (SSM) and non-SSM countries.

Main Objectives

To increase consistency in supervisory responses across EU institutions.
To support joint decision-making on capital and liquidity adequacy through colleges of supervisors.
To improve the quality and reliability of SREP outcomes by introducing a common framework and process.

Key Features of the Common SREP Framework

Common approach to all institutions, with proportionality through institution categorisation.
Common scoring definitions for risk and viability scores, using a 1–4 scale.
Focus on overall viability of institutions, with SREP outcomes used as triggers for early intervention and crisis management.
Supervisory judgment is central, with no rigid formulas or matrices, but guided by considerations.
Integration of risk assessments with recovery and resolution regimes.
Flexibility in application, with common elements and national discretion where appropriate.

Institution Categorisation

The EBA proposed four categories of institutions based on complexity and systemic importance:

Category	Monitoring Frequency	Assessment Frequency (SREP Elements)	Summary Frequency	Minimum Engagement Level
1 (G-SII, O-SII, other large institutions)	Quarterly	Annual	Annual	Ongoing engagement
2	Quarterly	Every 2 years	Annual	Ongoing engagement
3	Quarterly	Every 3 years	Annual	Risk-based engagement
4 (Small non-complex domestic institutions)	Quarterly	Every 3 years	Annual	Engagement every 3 years

Common Scoring and Assessment Elements

Viability scores and risk scores are used to evaluate the institution's overall status.
The Overall SREP score includes an 'F' grade indicating the institution is failing or likely to fail.
Business Model Analysis (BMA) is a core component, focusing on profitability, strategic plans, and risk drivers.
Risk assessment includes inherent risk, controls, and forward-looking analysis.
Supervisory measures are based on the severity and criticality of findings, including restrictions on dividends, capital buffers, and liquidity requirements.

Assessment of Capital and Liquidity Adequacy

Capital adequacy is evaluated using own funds requirements, capital conservation buffer, TSCR, and stress testing.
Liquidity adequacy is assessed through LCR, NSFR, and stress testing on maturity mismatches and survival periods.
Both assessments are subject to joint decisions for cross-border groups and supervisory judgment.

Early Intervention Measures

Measures are proportionate to the gravity of deficiencies.
Can be adopted at any point during the SREP cycle or after on-site inspections.
Aim to restore compliance and enhance prudential soundness.
May support macro-prudential measures for specific institutions.

Cross-Border Implications

Consolidating supervisors must perform initial assessments on the group level.
Competent authorities must assess on the entity level (solo or sub-consolidated).
Group risk assessment reports are required under Article 113 of CRD.

Next Steps

Public consultation runs until 7 October 2014.
Finalisation of Guidelines planned for December 2014.
Implementation by 1 January 2016, applicable to the 2016 SREP cycle.
'Comply or explain' approach for national implementation.
Transitional arrangements:
- Supervisory benchmarks and quantitative requirements linked to LCR and NSFR are not required until those regulations are in place.
- Inter-risk diversification and composition of own funds under Pillar 2 will be addressed later due to potential country-specific impacts.

Monitoring and Follow-Up

EBA will monitor the consistency and methodology of supervisory reviews.
Peer reviews, formal mediation, and statutory obligations will be used to benchmark and improve SREP application.
Guidelines and Single Supervisory Handbook will be amended and updated based on monitoring outcomes.

Questions for Consultation

Are the guidelines sufficient in specifying the SREP process? Should the EBA aim for greater harmonisation or flexibility in certain areas?
Do you agree with the proportionate approach for different categories of institutions?
Are there other drivers of business model success or failure that competent authorities should consider in BMA?
Does the risk categorisation provide appropriate coverage for supervisory risk assessments?
Do you agree with the use of a standard approach for articulating additional own funds requirements?
Should competent authorities be granted additional transition periods for meeting certain capital and liquidity provisions?