2013年-ECB欧洲央行_Bank_structural_reform_-_Position_of_the_Eurosystem_on_the_Commissions_consultation_document_6页_126kb

Summary of the Eurosystem's Position on the Commission's Consultation Document on Bank Structural Reform

Core Content

The Eurosystem has responded to the European Commission's Consultation Document on the "Liikanen Report", which outlines five key recommendations for bank structural reform. The Eurosystem generally supports the report's objectives, emphasizing the importance of enhancing the resilience of the financial system and improving the resolvability of financial institutions in Europe. The reform measures aim to safeguard the diversity of the EU banking sector and align with the existing universal banking model.

Main Recommendations and Eurosystem's Position

1. Mandatory Separation of Proprietary Trading and Other Significant Trading Activities

• Support: The Eurosystem supports the idea of separating high-risk trading activities from deposit-taking functions.
• Purpose: This separation aims to protect depositors, reduce cross-subsidization, limit complexity, and enhance resolvability.
• Concerns:
  • The criteria for separation should be clear and enforceable.
  • Financial innovation may blur boundaries, requiring further analysis.
  • The Eurosystem cautions against relying solely on IFRS for separation, as it may allow banks to manipulate financial transactions.
  • It stresses the need for a consistent EU-wide framework, with the EBA and ECB playing a central role in developing binding standards.
  • The potential for spillover effects between entities remains, especially in stress scenarios.
  • The issue of size and interconnectedness must be addressed to prevent systemic risks.

2. Additional Structural Separation Conditional on Recovery and Resolution Plans (RRPs)

• Support: The Eurosystem supports the idea of additional structural separation, provided it is conditional on the feasibility of RRPs.
• Purpose: This would help reduce intra-group contagion and improve resolvability.
• Concerns:
  • Structural measures may be circumvented through innovation.
  • Supervisors must ensure that these measures remain effective and are adapted as needed.
  • Communication to the public should be clear and comprehensive.
  • The EBA should develop a general framework and guidance for resolvability assessments, consistent with the Financial Stability Board's standards.

3. Designated Bail-in Instruments

• Support: The Eurosystem supports the introduction of bail-in instruments as a resolution tool.
• Purpose: This reduces the reliance on taxpayer funds and enhances market discipline.
• Concerns:
  • The proposal should align with the upcoming Bank Recovery and Resolution Directive.
  • A minimum bail-in requirement for systemic banks should be considered.
  • The Eurosystem recommends that the EBA assess the impact of such instruments and whether they should be prohibited or limited in the banking sector.
  • Further work is needed on the practical and operational implications of bail-in.

4. Increase of Capital Buffers for Trading Activities and Stricter Real Estate Lending Rules

• Support: The Eurosystem supports the idea of increasing capital buffers for trading activities and revising real estate lending rules.
• Purpose: To ensure that banks have sufficient capital to absorb losses and to improve risk assessment.
• Concerns:
  • The exact nature of the capital buffer (e.g., whether it is a minimum requirement or subject to distribution restrictions) needs clarification.
  • The Eurosystem highlights the need for a comprehensive impact assessment across the EU, considering existing reforms like the Basel III framework.
  • A robust floor for internal model-based risk-weighted assets (RWAs) should be defined and aligned with Basel III developments.
  • The leverage ratio should be clarified in relation to the risk-based framework.
  • The Eurosystem supports the inclusion of LTV and LTI ratios in macro-prudential instruments but opposes uniform caps across all EU member states.
  • It advocates for flexibility in macro-prudential tools while promoting EU-level harmonization of statistical data.
  • Ongoing work by the BCBS on large exposures should be completed before introducing new measures, ensuring alignment with the Bank Recovery and Resolution Directive.

5. Strengthening Governance and Control of Banks

• Support: The Eurosystem supports measures to strengthen governance and control, particularly in relation to remuneration.
• Purpose: To reduce excessive risk-taking and align incentives with long-term stability.
• Concerns:
  • The Eurosystem emphasizes the need for international coordination in remuneration policies, under the Financial Stability Board.
  • It supports variable remuneration in the form of bail-in bonds and capped bonuses to limit risk-taking incentives.
  • The Eurosystem believes that harmonizing remuneration frameworks is essential to ensure market discipline while retaining the ability to attract top talent.

Key Information

• The Eurosystem supports the general direction of the Liikanen Report but stresses the need for comprehensive impact assessments.
• Coordination at both EU and international levels is crucial to avoid regulatory arbitrage and ensure a level playing field.
• The role of the EBA is central in developing binding standards and guidance for implementation.
• Size and interconnectedness of banks must be considered in structural reforms to prevent systemic risks.
• Governance and remuneration reforms are seen as critical for long-term financial stability and risk management.

Conclusion

The Eurosystem's position reflects a balanced approach, supporting structural reforms while emphasizing the need for careful implementation, coordination, and impact assessment. It advocates for a consistent and resilient financial system that maintains diversity and aligns incentives with long-term stability.