Dear Mr Andrea Enria,
In April 2016, the Basel Committee on Banking Supervision (BCBS) published Standards on Interest Rate Risk in the Banking Book (IRRBB). After several years of in-depth discussions amongst regulators as well as with the industry, the BCBS re-affirmed its previous, long-standing position that IRRBB is more appropriately captured in a Pillar 2 framework.
The BCBS also concluded that IRRBB is heterogeneous by nature and that the complexities involved in formulating a standardised measure for IRRBB would not be sufficiently accurate and risk-sensitive to be used as a tool for setting regulatory capital requirements. The BCBS conclusions are particularly pertinent for Europe given the heterogeneity of the IRRBB of European banks due to the different business models and environments they operate in.
The BCBS Standards are largely consistent with the current Guidelines on the Management of Interest Rate Risk arising from non-Trading Activities published by the European Banking Authority (EBA) in May 2015. The BCBS Standards update the principles for the management of IRRBB, notably the definition as well as the threshold applicable to the Standard Outlier Test (SOT) whose role is to identify banks’ with IRRBB exposures that require supervisory engagement and possibly corrective measures.
We understood from the recently published EBA 2017 work programme that the EBA will revise its current Guidelines to incorporate the Basel Standards. To ensure consistent application in the EU, we believe the EBA Guidelines should be clear on the following principles:
The impact of any proposed changes to the outlier test on European banks’ business models should in our view be carefully analysed. We also believe that some adjustments to the BCBS Standards disclosure requirements should be made to ensure the provision of valuable public information.
The EBF would welcome the opportunity to contribute to the considerations of how to incorporate the BCBS IRRBB Standards in the European regulation. We would very much appreciate to meet with you or your services to provide our views on the implementation of the Basel standards in the EU in more details.
Yours sincerely,
Wim MIJS
Chief Executive
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]]>BRUSSELS, 4 February 2021 – The European Banking Federation has responded to the European Banking Authority’s consultation on incorporating ESG risks into the governance, risk management and supervision of credit institutions and investment firms.
Find the EBF response to this consultation by clicking the ‘full document’ button below:
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FOR MORE INFORMATION:
Sustainable Finance page on the EBF website: CLICK HERE
Denisa Avarmaete, Senior Policy Adviser, Sustainable Finance, EBF
d.avarmaete@ebf.eu
MEDIA CONTACTS:
Ruta Barthet, Senior Communications & Media Officer, EBF
r.barthet@ebf.eu, +32 492 46 73 04
Raymond Frenken, Director of Communications, EBF
r.frenken@ebf.eu +32 2 508 3732
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ABOUT THE EUROPEAN BANKING FEDERATION:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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]]>Executive summary
In April 2016, the Basel Committee on Banking Supervision (BCBS) published the Standards on Interest Rate Risk in the Banking Book (IRRBB).
The forthcoming Capital Requirements Directive (CRD 5) and Capital Requirements Regulation (CRR 2) implement the BCBS Standards in the regulatory framework of the European Union. The final text of the so-called Risk Reduction Measures (RRM) package including CRD 5 / CRR 2 was adopted by the European Parliament in mid-April 2019 and will need to be applied in two years.
CRD 5 mandates the European Banking Authority (EBA) to complement the directive by drafting Regulatory Technical Standards (RTS) to submit to the European Commission or by issuing guidelines within one year after the publication. In this context, the European banking industry, through the European Banking Federation (EBF), decided to articulate this memorandum which specifies the ”European Banking Industry Common Understanding of CSRBB as defined by EBA Guidelines”. The EBF uses this paper to provide its views on the EBA Guidelines’ definition of CSRBB, the monitoring process and the assessment of the framework.
Lukas Bornemann, Prudential Policy and Supervision, l.bornemann@ebf.eu
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EBF Head of Banking Supervision Gonzalo Gasos with Slovenian winners of the 2019 European Money Quiz finals
Thank you, Stanislava Zadravec Caprirolo, for your invitation to participate in the Banking Conference of the Bank Association of Slovenia. I am pleased to visit Slovenia, also because it is a country with a keen interest in finance. That became obvious in the European Money Quiz, the financial literacy competition that we organise annually in the European Banking Federation with the participation of more than one hundred thousand students from across the EU. Two teenagers from the Slovenian team were placed first in the second edition last month. My deepest congratulations!
The last time I was in Ljubljana was in 2010 when I gave a presentation in the program on home-host cooperation. Rereading my slides, I realise how much the supervisory architecture has changed towards a European model and how little the banking system has moved from its national based model since then. In 2010, the first steps of the European System of Financial Supervisors were being taken. I claimed in my presentation that further bank consolidation would contribute to the Single Market’s integration and that we all should encourage the emergence of cross-border banking groups.
– This will be the first topic of my speech, the longstanding cross-border ambition in European banking and supervision;
– Secondly, I will raise some facts about the supervision of banks as businesses in the new regulatory framework;
– Number three, I would like to assess the interaction between regulation and supervision;
– Finally, I will refer to the role of the internal assessment of banks as the place where business and supervision come together, offering an opportunity to conduct business-conscious oversight in the post-regulatory reform era.
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
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]]>BRUSSELS, 5 October 2020 – The European Banking Federation notes the report recently published by Europe’s central banks regarding an integrated data reporting system as envisaged in Article 430c of the Capital Requirements Regulation (CRR2). The EBF appreciates this ECB initiative as a timely step to trigger discussion among European authorities and between these and the banking industry.
The European System of Central Banks (ESCB) published its report[1] as input to a feasibility study currently being conducted by the European Banking Authority (EBA) on an integrated reporting system for the collection of statistical, resolution and prudential data from banks. The ESCB report proposes a number of measures addressing both lawmakers and the banking industry intentions to make bank reporting more efficient. EBA has included the feasibility study in its 2021 Work Programme as an objective for the third quarter.
The EBF has repeatedly underlined the need for an integrated and standardised framework for data reporting in the European Union. More than merely the volume of reporting requirements, the issue is the lack of efficiency and consistency among the key stakeholders in the design and transfer of data from banks to supervisors and regulators, and duplication of reporting between supervisors. An efficient solution will need to consider four principles: define once, report once, share information and enhance governance.
Europe’s banking sector is fully committed to working closely with authorities and is keen to fostering synergies by aiming for integrated and standardised reporting requirements. The EBF stands ready to discuss in detail the ESCB proposed views as well as the views of EBA and other relevant authorities.
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Raymond Frenken, Director of Communications
r.frenken@ebf.eu +32 496 52 59 47
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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MALTA, 5 May 2017 — European banks, through the Board of the European Banking Federation, today reaffirmed their commitment to supporting the European project through actively and responsibly financing businesses and households. The Board welcomed continued evidence of easing bank credit standards and increasing loan activity in the euro area, as demonstrated again in the first quarter by the quarterly Bank Lending Survey of the European Central Bank.
Given the particular significance of bank finance for Europe’s economy the EBF Board called on national and European policymakers for proper calibration when it comes to the finalisation of the wide range of regulatory measures still currently under discussion in the European Union. This is necessary so that banks can continue their financing commitment and support growth and jobs.
“We need to make sure that the international competitiveness of the European banking sector is not damaged. It is up to policymakers now to finalise the regulatory agenda and strike the right balance, avoiding undue impact on the financing of households and companies while ensuring the development of a safe, sustainable and competitive European financial services industry that benefits all our economies.”
Customers expect banks to protect their personal data. Data protection is at the core of trust in financial institutions. While European banks fully embrace innovation in their services and value competition in the market, the Board of the EBF warns that an inappropriate changes of proposed technical standards for electronic payments would put at risk the integrity of customer data, jeopardises the level playing field in European payment services and places a disproportionate burden on banks in the implementation of unnecessary technical solutions.
The Board calls on the European Commission to adopt – without amendments – the delegated act proposed by the European Banking Authority (EBA) for electronic payment services under the second European Payment Services Directive, known as PSD2. Deviating from the EBA recommendations would clearly go against the objectives of enhancing consumer protection and improving security of payment services across the European Union.
Through the Board of the EBF European banks reaffirm their commitment to serving Europe’s economy and to working with households and businesses – including SMEs – on their finances.
National and European policymakers need to recognise that banks are held back from fully delivering on this commitment as long as they continue to face regulatory uncertainty.
Particular sources of concern for banks are the leverage ratio; the implementation of the minimum requirement for own funds and eligible liabilities (MREL); the Net Stable Funding Ratio (NSFR); and the Fundamental Review of the Trading Book (FRTB). Financing of the European economy can be substantially impacted if these are not carefully and proportionally calibrated.
The Board calls on EU policymakers to agree the EU Risk Reduction Package in a way that respects the balance between economic growth and financial regulation. European banks generally see the package as an opportunity to make regulation more proportionate, less burdensome and more manageable.
However certain elements of the package, in particular those regarding capital requirements, overlap with measures currently under discussion at the Basel Committee on Banking Supervision. The Board calls on policymakers to put on hold EU decisions on these measures until international decisions on the Basel IV framework have been finalised.
Addressing the global discussions in the Basel Committee, the Board of the EBF continues to fear that Basel IV could have significant negative consequences for bank financing in Europe if it is adopted with ill-calibrated parameters, in particular an output floor. The EBF Board strongly believes that European policymakers should only support an agreement on international standard if it is not detrimental to the banks’ capacity to finance businesses and households and hence does not jeopardise European growth perspectives.
Furthermore the Board calls on European policymakers to fully take into account the specificities of EU bank finance as opposed to the structure of financing in the United States, particularly regarding mortgages and corporates.
While the Board recognised the significant progress being made by the Single Resolution Mechanism (SRM) it noted the implementation of the full range of measures included in the SRM requires careful assessment of the potential impact and unintended effects on the EU economy. The Board highlighted the importance of building a constructive dialogue between the industry and the Single Resolution Board at a critical moment in its development.
Beyond the most urgent topics on the regulatory agenda, the Board also discussed longer-term topics such as the upcoming negotiations between the EU and the United Kingdom on its EU membership and the pending discussions on future cooperation between the EU27 countries and the UK. With regards to the EU plans for creating a Capital Markets Union, the Board unanimously agrees that the European Commission needs to develop a more ambitious approach, capital market financing being needed going forward to finance the economy as a complement to bank financing.
While in Malta the European Banking Federation and the Malta Bankers’ Association organised a joint conference on key issues affecting smaller European banks.
Hosted at the Malta Financial Services Authority the conference addressed the need for proportionality in regulation; digitalisation; and unintended constraints to correspondent banking, with the participation of the European Banking Authority, the European Commission and the European Central Bank. Prof. Edward Scicluna, Finance Minister of Malta, which currently holds the presidency of the EU, closed the conference with a reflection on the need to fine-tune EU regulation for banks.
Raymond Frenken, Head of Communications, +32 496 52 59 47, r.frenken@ebf.eu
The European Banking Federation is the voice of the European banking sector, uniting 32 national banking associations in Europe that together represent some 4,500 banks – large and small, wholesale and retail, local and international – employing about 2.1 million people. EBF members represent banks that make available loans to the European economy in excess of €20 trillion and that securely handle more than 300 million payment transactions per day. Launched in 1960, the EBF is committed to creating a single market for financial services in the European Union and to supporting policies that foster economic growth.
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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]]>BRUSSELS, 17 December 2020 – The European Banking Federation notes the publication this week by the European Banking Authority (EBA) of its updated assessment[1] of the impact of the forthcoming Basel III agreement implementation on the capital requirements of Europe’s banks.
The EBA study shows that the impact on banks’ balance sheets remains very significant (+ 18.5%, and even more for Europe’s largest banks which account for most of the region’s assets: + 22.4%). The assessment still amounts to a capital shortfall of between €33 billion and €52.2 billion, most of it in large banks. Important is to note that the EBA’s analysis does not consider any detailed quantification of the financial impact from the Covid-19 pandemic, although its simulations suggest further material increases in capital shortfalls.
Contrary to the study[2] published by Copenhagen Economics, the EBA study still does not take into account the current capital ratios of banks. Banks indeed typically operate with capital buffers, e.g., as capital ratios fluctuate as part of the daily business and due to expectations from supervisors as well as investors. The current crisis has laid bare the importance of the management buffers. Thanks to the management buffer European banks have been able to withstand a major economic shock and keep up the level of lending. Therefore, the EBF reiterates that the EBA should use as main reference the sheer amount of capital needed to restore the current capital ratios.
It appears therefore essential that the European Commission implement the Basel IV framework at the European level with no significant adverse impact on any jurisdiction while respecting the international level playing field in banking and taking into consideration the European specificities.
The EBF believes that appropriate implementation of Basel IV is even more important in the context of the recovery from the COVID-19 crisis for banks to be able to continue providing
the very much needed financing for corporates, SMEs, and households. Doing it diffidently would put at risk the chance of a sustainable recovery in Europe.
To mitigate this adverse impact, the EBF has identified a number of concrete implementational options to make the package more suited to the European specificities, including the possibility to implement the output floor as a separate capital requirement where only internationally agreed capital buffers are applied (the so-called parallel stack approach), solutions to avoid penalising unrated corporates which form the vast majority of companies in Europe, a cap to the operational risk requirement in line with other jurisdictions, as well as maintaining the options already enacted in European legislation (CVA, SME supporting factor, etc.).
[1] https://eba.europa.eu/sites/default/documents/files/document_library/Publications/Reports/2020/961423/Basel%20III%20reforms%20-%202019Q4%20update%20and%20Covid%20impact.pdf
[2] https://www.copenhageneconomics.com/publications/publication/eu-implementation-of-the-final-basel-iii-framework#:~:text=In%20December%202017%2C%20the%20Basel,for%20different%20types%20of%20portfolios.
MEDIA CONTACT:
Ruta Barthet, Senior Communications and Media Officer
r.barthet@ebf.eu, +32 492 46 73 04
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Raymond Frenken, Director of Communications
r.frenken@ebf.eu +32 2 508 3732
ABOUT THE EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere. Website: www.ebf.eu
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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]]>BRUSSELS, 22 December 2020 – The Official Journal of the European Union has today published the Delegated Regulation (EU) 2020/2176 on the prudential treatment of software assets for EU banks. As a result, EU banks will no longer have to fully deduct prudently valued software and IT systems from Common Equity Tier 1 items. The new rules will enter into force on 23 December 2020.
Lawmakers and the European Banking Authority (EBA) have partially tackled the mismatch between prudential rules and the digitalisation of the EU banking sector. The EBA has delivered a prudent, pragmatic, and effective proposal in October this year. The suggested rules partially remove the longstanding penalisation to European banks’ investments into software, relieving part of the regulatory cost. We much welcome that the European Commission and legislators have validated EBA’s approach and allow the new rules to take effect without delay.
“We at EBF have highlighted for a long time that capital rules should not punish investments in IT and software. Continuous and state-of-the-art digitalisation is key for our sector’s efficiency, competitiveness, and profitability, but also for its digital operational resilience as well. For much too long EU banks investing in software have had to do so at much higher cost than their non-EU peers and competitors. This is a step in the right direction,” says Wim Mijs, Chief Executive Officer of the European Banking Federation.
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MEDIA CONTACTS:
Ruta Barthet, Senior Communications & Media Officer
r.barthet@ebf.eu, +32 492 46 73 04
Raymond Frenken, Director of Communications
r.frenken@ebf.eu +32 2 508 3732
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ABOUT THE EUROPEAN BANKING FEDERATION:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
The post A step in the right direction: prudential rules for EU banks’ software assets are adjusted appeared first on EBF.
]]>BRUSSELS, 1 September 2020 – The European Banking Federation has responded to the European Securities and Markets Authority (ESMA) consultation on Guidelines on Outsourcing to Cloud Service Providers and has called for a strong alignment of the ESMA guidelines with the existing guidelines of the European Banking Authority (EBA) in order to prevent a disproportionate burden for financial institutions covered by both regimes.
Looking at the already published EBA Guidelines on outsourcing arrangements from 25 February 2019, European banks already face a dedicated set of requirements for outsourcing, including cloud computing services.
Implementation of the guidelines by the national competent authorities in European member states provides the framework for banks’ cloud adoption. The EBF considers it of utmost importance to provide banks with a consistent supervisory framework, avoiding diverging requirements across the EBA and ESMA guidelines.
There should be one single set of rules. To avoid an excessive unnecessary burden and disproportionate effects on dual regulated firms under both sets of guidelines, European banks encourage an explicit reference in the ESMA guidelines stating that banks which are compliant with the EBA requirements should also be considered compliant by the national competent authority in regard to the ESMA rules. The EBF invites ESMA to consider the respective example of a reference such as paragraph 4 in the introduction of the EIOPA guidelines on outsourcing to cloud service provides, as issued in February 2020.
The EBF welcomes ESMA’s understanding that the main risks associated with cloud outsourcing are similar across sectors. ESMA has considered the recent guidelines published by EBA and EIOPA. However, EBF has identified a number of details within the ESMA guidelines where presentation and/or details of the requirements in question deviate from the established EBA guidelines. EBF invites ESMA to reconsider the identified deviations and to stronger align with existing EBA requirements. Where considered helpful, further exploratory guidance – in turn required to be aligned with EBA guidelines – is suggested. Such alignment will prevent detrimental burdens for banks – in terms of time, work effort and respective costs – by enabling streamlined compliance with both EBA and ESMA supervisory framework. A fragmented approach will otherwise make it difficult for firms who are regulated by both the EBA and ESMA, ultimately impairing on the ability to adopt cloud banking at scale.
Click here for the EBF response submitted in the ESMA consultation
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For more information:
Julian Schmücker, Policy Adviser Digital Innovation, j.schmucker@ebf.eu
For more about the EBF Cloud Banking Forum:
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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]]>BRUSSELS, 30 July 2020 – The EBF has responded to the consultation paper of the European Banking Authority (EBA) on draft Guidelines on the appropriate subsets of sectoral exposures to which competent or designated authorities may apply a systemic risk buffer in accordance with the Capital Requirements Directive.
Key concerns of the EBF members are related to a high degree of complexity of the proposal, the need to ensure consistency in the implementation of the framework, and the need to keep the operational burden for banks low. Therefore, the EBF calls on the EBA to consider the following key concerns:
EBF Adviser:
Lukas Bornemann, Policy Adviser
l.bornemann@ebf.eu, +32 2 313 32 73
About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from 45 countries. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere. Website: www.ebf.eu Twitter: @EBFeu
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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