EBA欧洲银行-EBA-Report-on-convergence-of-supervisory-practices-2017_56页_1mb

Summary of the EBA Report on Convergence of Supervisory Practices

Core Content

This report, issued by the European Banking Authority (EBA) in November 2017, provides an overview of the progress and challenges in achieving supervisory convergence across the European Economic Area (EEA) as per Article 107 of the Capital Requirements Directive (CRD). It is the third annual convergence report and highlights the EBA's efforts in monitoring and promoting consistent supervisory practices among competent authorities.

Main Tools for Supervisory Convergence

The EBA employs several tools to support supervisory convergence:

• Regulatory Products: These include guidelines, recommendations, and opinions that establish common standards.
• Training: The EBA expands its training activities, including online and residential formats, to ensure consistent application of supervisory practices.
• Monitoring and Assessment: This encompasses peer reviews, desk-based reviews, college monitoring, and bilateral convergence visits.

Bilateral Convergence Visits

• Introduced in 2016, these visits facilitate direct dialogue between EBA staff and competent authorities.
• In 2017, the EBA conducted a second round of visits, engaging with 11 competent authorities (3 SSM and 8 non-SSM).
• The visits focused on:
  • Implementation of SREP Guidelines.
  • Practical application of Business Model Analysis (BMA).
  • Setting of Pillar 2 Requirements (P2R) and Pillar 2 Guidance (P2G).
  • Changes in business models related to financial innovation and FinTech.

These visits help identify differences in interpretation and guide future revisions of the guidelines.

Main Areas of Convergence and Challenges

2.1 Implementation of SREP Guidelines

• Competent authorities have made good progress in implementing the SREP Guidelines and applying EBA recommendations.
• Key areas of focus include:
  • Business Model Analysis (BMA): The EBA assesses how BMA is applied in practice, identifying "good practices" (see Table 1).
  • Internal Governance: The EBA evaluates the effectiveness of internal governance structures and controls across institutions.
  • Internal Models: There is ongoing review and benchmarking of internal models to ensure consistency.

2.2 Capital Adequacy Assessments and TSCR

• Challenges remain in methodologies for capital adequacy assessments and determining institution-specific additional own funds requirements.
• Differences in approaches to using the Internal Capital Adequacy Assessment Process (ICAAP), risk taxonomies, and transparency in setting P2R have led to inconsistencies in communication and application.
• Despite these challenges, convergence is improving as authorities implement EBA recommendations and updates to the SREP framework.

Recovery Plan Assessments

3.1 Recovery Planning

• Comparative reports on recovery planning are being used to assess consistency in approaches.
• There are differences in how individual entities within groups are treated in recovery plans.
• Simplified obligations for recovery and resolution planning are being introduced, with P2G already implemented by many competent authorities, though with some divergences in approach.

Application of Supervisory Measures

4.1 P2R Analysis

• The EBA analyzed the range of P2R applied by competent authorities in 2015 and 2016 (see Figures 4 and 5).
• There is a narrowing of P2R ranges across authorities, indicating increased consistency.
• The EBA also evaluates the use of P2R for macroprudential purposes, highlighting the need for transparency.

4.2 P2G Analysis

• P2G is still in its early stages with limited experience and no common framework.
• Most competent authorities are setting P2G, but with differences in approach.
• Convergence is expected to increase as the common framework for P2G is introduced in the revised SREP Guidelines.

4.3 Other Supervisory Measures

• The EBA tracks the use of "other" supervisory measures based on SREP outcomes.
• These measures vary across authorities and institutions, but there is a trend towards more consistent application.

Colleges of Supervisors

5.1 Functioning of Colleges

• The EBA monitors the functioning of colleges of supervisors for major cross-border banking groups.
• This includes assessing the implementation of specific standards and guidelines, particularly those related to SREP reviews and recovery plan assessments.
• The process has shown continuous improvement over time, with a stronger link between colleges and supervisory convergence in the Single Market.

5.2 EBA's Role in College Discussions

• The EBA identifies and promotes topics for college discussions, such as the need for better clarification of scoring methods and the articulation of TSCR and OCR.
• These topics are included in the 2018 Colleges Action Plan (see Figure 9).

Policy Work Supporting Convergence

6.1 SREP Guidelines

• The EBA is updating the SREP Guidelines, incorporating lessons from previous assessments.
• Key updates include:
  • The use of supervisory stress testing in capital adequacy assessment.
  • Introduction of P2G.
  • Clarification of the role of viability scores.
• These updates are expected to be finalized in 2018 and apply from 1 January 2019.

6.2 Internal Governance and Models

• The EBA continues to refine internal governance practices, including remuneration, 'fit and proper' assessments, and diversity in board composition.
• Internal models are reviewed and benchmarked to ensure consistency and alignment with the Single Rulebook.

Training Activities

7.1 Expansion of Training

• The EBA is expanding its training offerings, including:
  • Residential training programs.
  • Online training facilities.
• The goal is to ensure that line supervisors across the EEA have a better understanding of EBA guidelines and can apply them consistently.

Key Findings and Outlook

• The EBA has made significant progress in achieving supervisory convergence, particularly in the areas of SREP implementation and recovery planning.
• Challenges persist in methodologies for capital adequacy and the determination of own funds requirements.
• The introduction of a common framework for P2G is expected to improve convergence in the coming years.
• Continuous improvement in the functioning of colleges of supervisors is evident, with a stronger alignment with the Single Market objectives.
• The EBA is actively engaged in policy development and training to further support supervisory convergence.