External author: Thomas Breuer

Transcription

1 EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCA C GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE SAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS NCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING TO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO ING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECO IPOL DIRECTORATE GENERAL FOR INTERNAL POLICIES ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs S ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE EGOV BANKING ECONOMIC UNION ECONOMIC GOVERNANCE GOVERNANCE SUPPORT BANKING UNIT UNION ECONOMIC GOV EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF D SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NR MIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNAN AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR RM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SG F ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs N MIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNAN EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DG RP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP NKING UNION ECONOMIC GOVERNANCE BANKING IUNION N - ECONOMIC DEPTH GOVERNANCE ANALYSIS BANKING UNION ECONOMIC GOVERNANCE BANKING UNION BA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ES MIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNAN GP EIP MTO SCP ESAs EFSM EDP AMR CSRs Capital AGS DGS EFSF shortfalls ESM ESBR EBA EWG in NCAs SSM NRAs SRM banks: MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM ED NRAs SRM MIP MTO NRP CRD SSM SGP How EIP MTO much SCP ESAs EFSM progress EDP AMR CSRs AGS has DGS EFSF been ESM ESBR made? EBA EWG NCAs NRAs SRM MIP MTO NRP CRD GS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG CP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs MIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNAN P MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP M SBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SR F ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs N External author: Thomas Breuer s EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DG MIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNAN NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SC BA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ES I GP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM ED MIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNAN NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD GS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA E O SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CS Provided at the request of the MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP E MIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION Economic ECONOMIC GOVERNANCE and Monetary BANKING Affairs UNION Committee ECONOMIC GOVERNAN SM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRA FSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS E CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP E EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MT MIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNAN CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR P EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP As SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SS GS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG MIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNAN October 2015 CP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs RNANCE ECON BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE BANKING UNION ECONOMIC GOVERNANCE EN BANKI P MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP M SBR EBA EWG NCAs NRAs SRM MIP MTO NRP CRD SSM SGP EIP MTO SCP ESAs EFSM EDP AMR CSRs AGS DGS EFSF ESM ESBR EBA EWG NCAs NRAs SR

2 IPOL EGOV DIRECTORATE-GENERAL FOR INTERNAL POLICIES ECONOMIC GOVERNANCE SUPPORT UNIT IN-DEPTH ANALYSIS Capital shortfalls in SSM banks: How much progress has been made? Author: Thomas Breuer Provided in advance of the public hearing of the Chair of the Single Supervisory Mechanism in ECON on 19 October 2015 Abstract The 2014 Comprehensive Assessment by the ECB identified and made public capital shortfalls at 25 major European banks. The banks concerned were required to submit a capital plan to the ECB and the national Competent detailing how the capital shortfall would be filled. Capital plans were to be implemented within six resp. nine months after 26 October Now that this time has passed, we examine the progress made by the banks required to take action. We also evaluate how far the Comprehensive Assessment achieved its objectives. ECON October 2015 EN PE

3 This paper was requested by the European Parliament's Economic and Monetary Affairs Committee. AUTHOR Thomas Breuer RESPONSIBLE ADMINISTRATOR Marcel Magnus Economic Governance Support Unit Directorate for Economic and Scientific Policies Directorate-General for the Internal Policies of the Union European Parliament B-1047 Brussels LANGUAGE VERSION Original: EN ABOUT THE EDITOR Economic Governance Support Unit provides in-house and external expertise to support EP committees and other parliamentary bodies in playing an effective role within the European Union framework for coordination and surveillance of economic and fiscal policies. This document is also available on Economic and Monetary Affairs Committee homepage, under section European Semester and Economic Dialogue at: Manuscript completed in October 2015 European Union, 2015 DISCLAIMER The opinions expressed in this document are the sole responsibility of the authors and do not necessarily represent the official position of the European Parliament. Reproduction and translation for non-commercial purposes are authorised, provided the source is acknowledged and the publisher is given prior notice and sent a copy. PE

4 CONTENTS List of abbreviations... 4 List of tables... 4 Executive summary Introduction A bank by bank analysis of the progress made Eurobank Ergasis Monte dei Paschi di Siena National Bank of Greece Banca Carige Cooperative Central Bank Banco Comercial Portuguȇs Bank of Cyprus Oesterreichischer Volksbanken-Verbund permanent tsb Veneto Banca Banco Popolare Banca Popolare di Milano Banca Popolare di Vicenza Piraeus Bank Credito Valtellinese Dexia Banca Popolare di Sondrio Hellenic Bank Münchener Hypothekenbank AXA Bank Europe C.R.H. Caisse de Refinancement de l Habitat Banca Popolare dell Emiglia Romagna Liberbank Conclusions References PE

5 LIST OF ABBREVIATIONS AQR Asset Quality Review AT1 Additional Tier 1 Capital CA Comprehensive Assessment CET1 Common Equity Tier 1 CoCo Contingent Convertibles ECB European Central Bank ELA Emergency Liquidity Assistance ESM European Stability Mechanism JST Joint Supervisory Teams LIST OF TABLES Table 1: Banks participating in the Comprehensive Assessment for which a capital shortfall has been identified... 7 Table 2: Capital raised before announcement of CA results by banks with a capital shortfall Table 3: Capital raised after announcement of CA results by banks with a capital shortfall PE

6 EXECUTIVE SUMMARY The 2014 Comprehensive Assessment (CA) conducted by the ECB identified and made public capital shortfalls at 25 European banks. Twelve out of these 25 banks had taken capital measures already before the publication of the CA results, so that there remained only thirteen banks which were required to take additional capital measures after publication of the CA results. The banks concerned were required to submit a capital plan to the ECB and the national Competent Authorities detailing how the capital shortfall would be filled. Capital plans were to be implemented within six resp. nine months after 26 October This analysis examines the progress made by the banks required to take action. We find that since then the capital plans have been implemented. During the Comprehensive Assessment capital measures of billion were implemented by the 25 banks. After the Comprehensive Assessment another 9.47 billion should have been raised. These goals were more or less achieved. In fact only 5.5 billion of new capital was issued in the markets. The rest was due to capital measures other than equity issuance, like asset sales, CoCo conversions, or regulatory capital requirement reductions. All in all, balance sheets of the banks concerned were indeed strengthened. This is an important achievement and improves the safety of European banks. Thus the first aim of the Comprehensive Assessment, strengthening of the banks balance sheets, has been achieved. The second aim was to strengthen transparency. The ECB and the EBA were largely transparent in the communication of the stress test method, although banks enjoyed a broad leeway, since they were allowed and encouraged to use their own internal models in working out the balance sheet implications of the macroeconomic scenarios. This impairs transparency to some degree and threatens the level playing field. The ECB and the EBA were fully transparent in the communication of the results. Unfortunately, after the publication of CA results the ECB never provided information to the public about the progress of capital measures. Such information was provided only by banks. A concluding statement by the ECB about the achievements of the measures following the Comprehensive Assessment is still wanting. The third aim was to build confidence: Can stakeholders be assured that, on completion of the identified remedial actions, banks will be soundly capitalised? Certainly stakeholders know that the banks with capital shortfalls in the two prescribed scenarios hold more capital after the completion of the exercise. The Comprehensive Assessment has definitely built confidence both in banks with and without capital shortfall identified. But it is open whether the banks now hold enough capital for other scenarios. For example, true losses of Greek banks in the 2015 crisis probably far exceed the projected balance sheet losses in the adverse stress scenario. This required the mobilisation of another 25 billion by the European Stability Mechanism for the recapitalisation of Greek banks and a second Comprehensive Assessment shortly after completion of the remedial action required by the 2014 Comprehensive Assessment. 5 PE

7 1. INTRODUCTION In 2014 the ECB conducted a Comprehensive Assessment (CA) of 130 banks. The CA consisted of an asset quality review (AQR) and a stress test. The AQR assessed the carrying value of banks assets as of 31 December The stress test examined the resilience of the banks in two hypothetical scenarios, a baseline and an adverse scenario. The stated objectives of the comprehensive assessment were to (i) strengthen banks balance sheets by repairing the problems identified through the necessary remedial actions; (ii) enhance transparency by improving the quality of information available on the condition of the banks; (iii) build confidence by assuring all stakeholders that, on completion of the identified remedial actions, banks will be soundly capitalised. 1 As reported by the ECB on 26 October 2014, the ECB conducted the comprehensive assessment to prepare for assuming banking supervision tasks in November This resulted in aggregate adjustments of 48 billion to participating banks' asset carrying values which will be reflected in their accounts or in supervisory capital requirements. Overall, the exercise has identified capital shortfalls for 25 banks, 2 totalling billion. Banks were required to fulfil the following capital requirements in the various parts of the comprehensive assessment. In the AQR banks were required to have a minimum Common Equity Tier 1 (CET1) ratio of 8%. Under the baseline scenario of the stress test banks were also required to have a minimum CET1 ratio of 8%. Under the adverse scenario of the stress test the CET1 ratio was required to be above 5.5%. The outcomes of the AQR may lead to an adjustment of the current carrying values (which in turn leads to an adjustment of the starting point of the stress tests), and possibly to modifications on the asset performance in the stress scenarios. Table 1 lists the 25 banks for which the ECB identified a capital shortfall in the CA. The third last column lists the capital shortfall identified in the CA. If between the reference date of the CA, 31 December 2013, and the conclusion of the stress test, 30 September 2014, any capital was raised by the banks concerned, that amount is displayed in the second last column of the table. The capital amounts to be raised after publication of the stress test results are given in the last column of Table 1. These are the numbers most relevant in the present analysis. Banks for which the European Commission approved a restructuring plan before 31 December 2013 were allowed to apply a dynamic balance sheet assumption. This assumption reflects the implementation of the approved material changes to the business model of the bank that typically includes some mix of asset disposal, organic deleveraging, and risk reduction. For these banks the supervisory response to the CA results is based on the lowest CET1 under the dynamic balance sheet assumption. 3 Regarding the consequences of the CA, the ECB stipulated that for each of the 25 institutions identified in Table 1, a capital plan will be submitted to the respective JST [Joint Supervisory Teams] within two weeks of the publication of this document, detailing how the capital shortfall will be filled. The JSTs will check that any such plans are sound and include the capital raising already undertaken by the participating banks with shortfalls. 4 Capital plans must show how any shortfalls will be addressed within six months after 26 October 2014 for those identified in the AQR or the baseline stress test scenario, and within nine months after 26 October 2014 for 1 See ECB (2014), p See ECB (2014), p Five banks had a restructuring plan approved after 31 December 2013 but before the conclusion of the stress test exercise. These banks were allowed to evaluate the stress scenarios under both the dynamic and the static balance sheet assumptions. Though the reported capital shortfall is based on the static balance sheet, the impact of restructuring/ the dynamic balance sheet are taken into account in the supervisory response. 4 See ECB (2014), p. 8. PE

8 those identified in the adverse stress test scenario. More than nine months have passed since the publication of the stress test results on 26 October Under the schedule announced by the ECB at the publication of results, by now all capital plans should have been submitted, approved and implemented. The present analysis examines how much progress has been made - between the publication of the stress test results on 26 October 2014 and 21 September by banks that were required to take action. Table 1: Banks participating in the Comprehensive Assessment for which a capital shortfall has been identified Bank Name CET1 ratio starting point CET1 ratio post AQR CET1 ratio baseline scenario CET1 ratio adverse scenario Capital shortfall ( billion) Net eligible capital raised ( billion) Capital shortfall post net capital raised ( billion) Eurobank 10.6% 7.8% 2.0% -6.4% Monte dei Paschi di Siena 10.2% 7.0% 6.0% -0.1% National Bank of Greece 10.7% 7.5% 5.7% -0.4% Banca Carige 5.2% 3.9% 2.3% -2.4% Cooperative Central Bank -3.7% -3.7% -3.2% -8.0% Banco Comercial Português 12.2% 10.3% 8.8% 3.0% Bank of Cyprus 10.4% 7.3% 7.7% 1.5% Oesterreichischer Volksbanken-Verbund 11.5% 10.3% 7.2% 2.1% permanent tsb 13.1% 12.8% 8.8% 1.0% Veneto Banca 7.3% 5.7% 5.8% 2.7% Banco Popolare 10.1% 7.9% 6.7% 4.7% Banca Popolare di Milano 7.3% 6.9% 6.5% 4.0% Banca Popolare di Vicenza 9.4% 7.6% 7.5% 3.2% Piraeus Bank 13.7% 10.0% 9.0% 4.4% Credito Valtellinese 8.8% 7.5% 6.9% 3.5% Dexia 16.4% 15.8% 10.8% 5.0% Banca Popolare di Sondrio 8.2% 7.4% 7.2% 4.2% Hellenic Bank 7.6% 5.2% 6.2% -0.5% Münchener Hypothekenbank 6.9% 6.9% 5.8% 2.9% AXA Bank Europe 15.2% 14.7% 12.7% 3.4% C.R.H. - Caisse de Refinancement de l Habitat 5.7% 5.7% 5.7% 5.5% Banca Popolare dell'emilia Romagna 9.2% 8.4% 8.3% 5.2% Nova Ljubljanska banka % 14.6% 12.8% 5.0% Liberbank 8.7% 7.8% 8.5% 5.6% Nova Kreditna Banka Maribor % 15.7% 12.8% 4.4% Total 10.0% 8.4% 7.2% 2.1% Source: ECB (2014), Table 1, p PE

9 2. A BANK BY BANK ANALYSIS OF THE PROGRESS MADE In this Section we report on the progress made by the 25 banks for which a capital shortfall was identified. The analysis will be based solely on public information, mainly on press releases published by the banks concerned. For the two Slovenian banks Nova Ljubljanska banka and Nova Kreditna Banka Maribor, the impact on 2014 of the restructuring measures already taken to improve structural profitability and the maintenance of retained earnings in banks will cover the shortfalls identified, so that the ECB required no additional action. Therefore these two banks will not be included in the analysis of this Section. 2.1 Eurobank Ergasis In the Comprehensive Assessment the ECB identified a capital shortfall of 1.76 billion for Eurobank under the static balance sheet assumption. Under the dynamic balance sheet assumption, Eurobank has no or practically no shortfall taking into account net capital already raised in As a result, Eurobank s CET1 ratio amounted to 14.2% as of 31 March In the first six months of 2015, as a result of deposit withdrawals and reduction of wholesale secured funding, Eurobank received Emergency Liquidity Assistance (ELA) funding amounting to 22.9 billion by 30 June In total the bank s funding from the Eurosystem financing facilities was 32.7 billion. The capital restrictions imposed in July 2015 have consequences on non-performing loans and CET1 which the bank cannot estimate reliably. 8 These are to be assessed in a new Comprehensive Assessment performed by the ECB on the four systemic Greek banks. Potential capital shortfalls of Greek banks revealed in this new CA are to be covered by a buffer of 25 billion provided by the European Stability Mechanism (ESM), as agreed in the Memorandum of Understanding of 19 August Monte dei Paschi di Siena In the Comprehensive Assessment the ECB identified for Banca Monte dei Paschi di Siena a capital shortfall of 4.25 billion under the dynamic balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Monte dei Paschi di Siena carried out additional capital measures amounting to billion, thereby reducing the capital shortfall to billion. 9 Unlike some other Italian banks in the Comprehensive Assessment, no additional capital measures were taken for Banca Monte dei Paschi di Siena, which would not already have been reflected in the CA results published by the ECB. 10 On 5 November 2014 Banca Monte dei Paschi di Siena announced a rights issue of up to 2.5 billion, further capital measures to raise about billion, and requested to reduce the capital shortfall by billion, which was the difference between the expected pre-provision profit for 2014 and the preprovision profit 2014 in the adverse scenario See the press release of Eurobank, dated 26 October See the press release of Eurobank, dated 3 August See the press release of Eurobank, dated 3 August See the press release of Eurobank, dated 3 August See the press release of Monte dei Paschi di Siena, dated 26 October See the press release of Banca d Italia, dated 26 October See the press release of Monte dei Paschi di Siena, dated 5 November PE

10 On 11 February 2015 Monte dei Paschi di Siena announced it has decided to increase the size of the intended rights issue, from EUR 2.5bn up to EUR 3 bn in order to have a capital buffer against the transitional CET1 ratio required under the SREP. 12 On 14 May 2015 Banca Monte dei Paschi di Siena announced the ECB approved the 3 billion rights issue and the subsequent reimbursement of 1.07 billion of State Aid it received. 13 On 22 June 2015 Monte dei Paschi di Siena announced the completion of its share capital increase by billion National Bank of Greece In the Comprehensive Assessment the ECB identified for National Bank of Greece a capital shortfall of 0.93 billion under the static balance sheet assumption. Under the dynamic balance sheet assumption, National Bank of Greece has no or practically no shortfall taking into account net capital already raised in As a result, Eurobank s CET1 amounted to 13.6% as of 31 December In the first six months of 2015, as a result of deposit withdrawals and reduction of wholesale secured funding, Eurobank received Emergency Liquidity Assistance (ELA) funding amounting to 17.6 billion by 30 June In total the bank s funding from the Eurosystem financing facilities was 27.6 billion. The capital restrictions imposed in July 2015 have consequences on non-performing loans and CET1 which the bank cannot estimate reliably. 18 These are to be assessed in a new Comprehensive Assessment performed by the ECB on the four systemic Greek banks. Potential capital shortfalls of Greek banks revealed in this new CA are to be covered by a buffer of 25 billion provided by the European Stability Mechanism (ESM), as agreed in the Memorandum of Understanding of 19 August Banca Carige In the Comprehensive Assessment the ECB identified for Banca Carige a capital shortfall of billion under the static balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Banca Carige carried out additional capital measures amounting to billion, thereby reducing the capital shortfall to billion. 19 Unlike some other Italian banks in the Comprehensive Assessment, no additional capital measures were taken for Banca Carige, which would not already have been reflected in the CA results published by the ECB. 20 At the publication of the CA results on 26 October 2015 Banca Carige announced a share capital increase of at least billion, the disposal of Carige s assets operating in the insurance business, and the buyback of the subsidiary banks non-controlling interest. On 19 March 2015 Banca Carige announced a billion share capital increase. 21 On 29 June 2015 Banca Carige announced the completion of the pre-emtive offering of its shares, with 99.83% of the shares underwritten for a total of 0.84 billion See the press release of Monte dei Paschi di Siena, dated 11 February See the press release of Monte dei Paschi di Siena, dated 14 May See the press release of Monte dei Paschi di Siena, dated 22 June See the press release of National Bank of Greece, dated 27 October See the press release of National Bank of Greece, dated 23 March See the press release of National Bank of Greece, dated 3 August See the press release of National Bank of Greece, dated 3 August See the press release of Banca Carige, dated 26 October See the press release of Banca d Italia, dated 26 October See the press release of Banca Carige, dated 19 March See the press release of Banca Carige, dated 29 June PE

11 2.5 Cooperative Central Bank In the Comprehensive Assessment the ECB identified for Cooperative Central Bank, Cyprus, a capital shortfall of 1.17 billion under the static balance sheet assumption. Before completion of the Comprehensive Assessment, Cooperative Central Bank implemented measures increasing capital by 1.5 billion, thereby turning the capital shortfall into a capital surplus of 0.33 billion. 23 No further capitalisation was required after publication of the results of the Comprehensive Assessment. As of 31 December 2014 Cooperative Central Bank had CET1 ratio of 13.5% Banco Comercial Portuguȇs In the Comprehensive Assessment the ECB identified for Banco Comercial Portuguȇs, which had a restructuring plan approved by the European Commission before 31 December 2013, a capital shortfall of 1.14 billion under the dynamic balance sheet assumption. Before completion of the Comprehensive Assessment, Banco Comercial Portuguȇs lost another 0.01 billion in capital, thereby increasing the capital shortfall to 1.15 billion. 25 The Banco de Portugal noted that, in the specific case of Banco Comercial Portuguȇs, the stress test did not fully reflect the globally positive developments resulting from the implementation of the restructuring plan negotiated with the European Commission. Already before publication of the Comprehensive Assessment results Banco Comercial Portuguȇs has identified a set of measures to fully cover the shortfall, which were incorporated in the capital plan submitted to the ECB. 26 In March 2015 Banco Comercial Portuguȇs announced a capital increase by billion. 27 There were no further public statements by Banco Comercial Portuguȇs, by the Banco de Portugal or by the ECB as to whether this capital plan was accepted by the ECB. As of 31 December 2014 Banco Comercial Portuguȇs had CET1 ratio of 12.0% according to phased-in criteria Bank of Cyprus In the Comprehensive Assessment the ECB identified for Bank of Cyprus a capital shortfall of 0.92 billion. Due to share increases of 1 billion in September 2014, there was no capital shortfall at the publication of the results of the Comprehensive Assessment. 29 No further capitalisation was required after publication of the results of the Comprehensive Assessment. As of 30 June 2015 the CET1 ratio of Bank of Cyprus was at 14.9% See the ECB s Aggregate Report on the Comprehensive Assessment dated 26 October See the press release of Cooperative Central Bank, dated 30 March See the ECB s Aggregate Report on the Comprehensive Assessment dated 26 October Press release of the Banco de Portugal, dated 26 October Press release of Banco Comercial Portuguȇs, dated 23 March See the press release of Banco Comercial Portuguȇs, dated 2 February Press release of Bank of Cyprus, dated 27 October Press release of Bank of Cyprus, dated 26 August PE

12 2.8 Oesterreichischer Volksbanken-Verbund In the Comprehensive Assessment the ECB identified for Oesterreichischer Volksbanken-Verbund a capital shortfall of 0.86 billion. Between January and October 2014 there was no capital raised, so that the shortfall to be covered after the announcement of the CA results was unchanged. On 26 October 2014 Oesterreichischer Volksbanken-Verbund announced restructuring plans involving a split into a wind-up entity holding higher risk assets, which would return its banking license. The 44 banks of the sector would merge to 9 regional banks and 3 special banks continuing to serve the clients of the old Oesterreichischer Volksbanken-Verbund. On 4 July 2015 these plans were implemented, Oesterreichischer Volksbanken-Verbund ceased to exist as a bank and was succeeded by the wind-up entity immigon portfolioabbau. 2.9 permanent tsb In the Comprehensive Assessment the ECB identified for permanent tsb a capital shortfall of 0.85 billion under the static balance sheet assumption. There were no capital measures implemented in the first nine months of 2014, so that the final capital shortfall announced after the Comprehensive Assessment remained at 0.85 billion. On 25 October 2014 permanent tsb announced that it intends to cover the capital shortfall by 0.4 billion Contingent Convertible (CoCo) Notes included as part of the recapitalisation of the Group in 2011, asset sales, and by raising capital of an amount not specified. 31 On 27 April 2015 permanent tsb announced that it has successfully raised billion from capital markets by selling ordinary shares for 0.4 billion and issuing Additional Tier 1 (AT1) capital for billion. Permanent tsb would seek listing on the Irish and London stock exchanges Veneto Banca In the Comprehensive Assessment the ECB identified for Veneto Banca a capital shortfall of billion under the static balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Veneto Banca carried out additional capital measures amounting to billion, thereby turning the capital shortfall into a capital surplus of billion. 33 Unlike other Italian banks in the Comprehensive Assessment, no additional capital measures were taken for Veneto Banca, which would not have been already reflected in the results published by the ECB. 34 As of 31 December 2014 Veneto Banca had a CET1 ratio of 9.6%. 35 On 15 September 2015 Veneto Banca announced a capital increase up to a maximum of 1 billion to be implemented in the first half of See the press release of permanent tsb, dated 26 October See the press release of permanent tsb, dated 27 April See the press release of Veneto Banca, dated 26 October See the press release of Banca d Italia, dated 26 October See the press release of Veneto Banca, dated 11 February See the press release of Veneto Banca, dated 15 September PE

13 2.11 Banco Popolare In the Comprehensive Assessment the ECB identified for Banco Popolare a capital shortfall of 0.69 billion under the static balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Banco Popolare carried out additional capital measures amounting to 1.76 billion, thereby turning the capital shortfall into a capital surplus of 1.06 billion. 37 Additionally, Banco Popolare profited from a validation of its internal model for operational risk and the sale of the Banking Subsidiary Banco Popolare Croatia in the first six months of These measures had a CET1 impact of billion, bringing the excess capital to billion. 38 As of 31 December 2014 Banco Popolare had a CET1 ratio of 11.9% Banca Popolare di Milano In the Comprehensive Assessment the ECB identified for Banca Popolare die Milano a capital shortfall of billion under the static balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Banca Popolare di Milano carried out additional capital measures amounting to billion, thereby turning the capital shortfall into a capital excess of billion. 40 Additionally to the capital measures published by the ECB, Banca Popolare di Milano profited from a full removal of add-ons on capital requirements (for mortgage guarantees, loans to construction and read estate companies, and for operational risks) approved by the Bank of Italy 41 on 24 June 2014, and sale of a stake in the share capital of Anima Holding held by Banca Popolare di Milano. These measures had a CET1 impact of billion, bringing the excess capital to billion. 42 As of 31 December 2014 Banca Popolare di Milano had a CET1 ratio of 11.58% Banca Popolare di Vicenza In the Comprehensive Assessment the ECB identified for Banca Popolare di Vicenza a capital shortfall of billion under the static balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Banca Popolare di Vizenca carried out additional capital measures amounting to billion, thereby reducing the capital shortfall to billion. 44 Additionally to the capital measures published by the ECB, Banca Popolare di Vicenza saw the conversion of the 253 Euro million soft mandatory convertible bonds, which turned the capital shortfall identified in the CA into a capital excess of billion. 45 As of 31 December 2014 Banca Popolare di Vicenza had a CET1 ratio of 11.10% See the press release of Banco Popolare, dated 26 October See the press releases of Banco Popolare and of Banca d Italia, dated 26 October See the press release of Banco Popolare, dated 26 February See the press release of Banca Popolare di Milano, dated 26 October See the press release of the Banca d Italia, dated 26 October See the press releases of Banco Popolare and of Banca d Italia, dated 26 October See the press release of Banca Popolare di Milano, dated 10 February See the press release of Banca Popolare di Vicenza, dated 26 October See the press release of Banca Popolare di Vicenza, dated 26 October See the press release of Banca Popolare di Vicenza, dated 10 February PE

14 2.15 Piraeus Bank In the Comprehensive Assessment the ECB identified for Piraeus Bank a capital shortfall of 0.66 billion under the static balance sheet assumption. This number does not take into account the benefit of the potential conversion of deferred tax assets to deferred tax credit. Additional Piraeus Bank offered capital of 1.75 billion in April As a result, under the dynamic balance sheet assumption, Piraeus Bank has no shortfall. 47 Therefore no remedial action was required as result of the Comprehensive Assessment. In the first six months of 2015, as a result of deposit withdrawals and reduction of wholesale secured funding, Piraeus Bank received Emergency Liquidity Assistance (ELA) funding amounting to 22 billion by 30 June In total the bank s funding from the Eurosystem financing facilities was 37 billion. As of 30 March 2015 the CET1 ratio of Piraeus Bank was 11.7%. 49 The capital restrictions imposed in July 2015 have consequences on non-performing loans and CET1 which the bank cannot estimate reliably. 50 These are to be assessed in a new Comprehensive Assessment performed by the ECB on the four systemic Greek banks. Potential capital shortfalls of Greek banks revealed in this new CA are to be covered by a buffer of 25 billion provided by the European Stability Mechanism (ESM), as agreed in the Memorandum of Understanding of 19 August Credito Valtellinese In the Comprehensive Assessment the ECB identified for Credito Valtellinese a capital shortfall of billion under the static balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Credito Valtellinese carried out additional capital measures amounting to billion, thereby turning the capital shortfall into a capital surplus of billion. 51 Additionally, Credito Valtellinese sold its leasing buiness unit to Alba leasing in the first six months of This measure had a CET1 impact of billion, bringing the excess capital to billion. 52 As of 31 December 2014 Credito Valtellinese had a CET1 ratio of 11.0% Dexia Dexia was already under resolution when the Comprehensive Assessment was performed. The ECB identified a capital shortfall of 0.34 billion for Dexia under the dynamic balance sheet assumption. 54 Asset disposals during the first three quarters of 2014 had a CET1 impact of billion. In its communication of 26 October 2014, the ECB indicated that, taking into account the orderly resolution plan of the Group that benefits from a State guarantee, there was no need to proceed with a capital raising following the comprehensive assessment results See the press release of Piraeus Bank, dated 26 October See the press release of Piraeus Bank, dated 3 August See the press release of Piraeus Bank, dated 3 August See the press release of Piraeus Bank, dated 3 August See the press release of Credito Valtellinese, dated 26 October See the press releases of Credito Valtellinese and of Banca d Italia, dated 26 October See the press release of Credito Valtellinese, dated 11 February See the press release of Dexia, dated 26 October See the press release of Dexia, dated 26 October PE

15 2.19 Banca Popolare di Sondrio In the Comprehensive Assessment the ECB identified for Banca Popolare di Sondrio a capital shortfall of billion under the static balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Banca Popolare di Sondrio carried out additional capital measures amounting to billion, thereby turning the capital shortfall into excess capital amounting to billion. 56 Unlike other Italian banks in the Comprehensive Assessment, no additional capital measures were taken for Banca Popolare di Sondrio, which would not already have been reflected in the CA results published by the ECB. 57 As of 30 June 2015 Banca Popolare di Sondrio had a CET1 ratio of 10.2% Hellenic Bank In the Comprehensive Assessment the ECB identified a capital shortfall of 0.18 billion for Hellenic Bank, Cyprus, under the static balance sheet assumption. However, already before the finalisation of the CA Hellenic bank converted Convertible Capital Securities, thereby reducing the capital shortfall to billion. 59 On 31 October 2014 Hellenic Bank announced plans to raise 0.22 billion of new capital from two major shareholders. On 12 December 2014 Hellenic bank announced that it had raised through the successful completion of the Subscription and Presubscription Phase of the Bank s Rights Issue. 60 This more than covers the capital shortfall identified in the Comprehensive Assessment and brought the CET1 ratio to 12.8%. As of 30 June 2015 the CET1 ratio was 13.5% Münchener Hypothekenbank In the Comprehensive Assessment the ECB identified a capital shortfall of 0.23 billion for Münchener Hypothekenbank under the static balance sheet assumption. However, already before the finalisation of the Comprehensive Assessment Münchener Hypothekenbank raised capital by selling shares for a total of billion in its sector. This turned the capital shortfall into a surplus of 0.18 billion. 62 As of 31 December 2015 Münchener Hypothekenbank had a CET1 ratio of 12.5% AXA Bank Europe In the Comprehensive Assessment the ECB identified a capital shortfall of 0.20 billion for AXA Bank Europe under the static balance sheet assumption. However, already before the finalisation of the 56 See the press release of Banca Popolare di Sondrio, dated 26 October See the press release of Banca d Italia, dated 26 October See the press release of Banca Popolare di Sondrio, dated 7 August See the press release of Hellenic Bank, dated 26 October See the press release of Hellenic Bank, dated 12 December See the press release of Hellenic Bank, dated 31 August See the press release of Münchener Hypothekenbank, dated 26 October See the press release of Münchener Hypothekenbank, dated 14 April PE

16 Comprehensive Assessment AXA Bank Europe was provided with capital resources of billion by AXA Group. This turned the capital shortfall into a surplus of billion C.R.H. Caisse de Refinancement de l Habitat C.R.H. is among the few institutions in the Comprehensive Assessment with no banking credit risk: It was only subject to the policy, processes and accounting (PP&A) review. In the Comprehensive Assessment the ECB identified a capital shortfall of 0.13 billion for C.R.H. under the static balance sheet assumption. However, already before the finalisation of the Comprehensive Assessment the capital of C.R.H. was increased by 0.24 billion. This turned the capital shortfall into a surplus of 0.11 billion. 65 As of 31 December 2015 C.R.H. had a CET1 ratio of 10.19% Banca Popolare dell Emiglia Romagna In the Comprehensive Assessment the ECB identified for Banca Popolare dell Emiglia Romagna a capital shortfall of billion under the static balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Banca Popolare dell Emiglia Romagna carried out additional capital measures amounting to billion, thereby turning the capital shortfall into excess capital amounting to billion. 67 Unlike other Italian banks in the Comprehensive Assessment, no additional capital measures were taken for Banca Popolare dell Emiglia Romagna, which would not already have been reflected in the CA results published by the ECB. 68 As of 30 June 2015 Banca Popolare dell Emiglia Romagna had a CET1 ratio of 11.5% Liberbank In the Comprehensive Assessment the ECB identified for Liberbank, Spain, a capital shortfall of billion under the dynamic balance sheet assumption. Already before the finalisation of the Comprehensive Assessment Liberbank carried out additional capital measures amounting to 0.64 billion, thereby turning the capital shortfall into excess capital amounting to 0.6 billion. 70 No additional capital measures were required for Liberbank. 71 As of 30 June 2015 Liberbank had a CET1 ratio of 13.4% See the press release of AXA Bank Europe, dated 26 October See the press release of C.R.H., dated 27 October See the press release of Münchener Hypothekenbank, dated 14 April See the press release of Banca Popolare dell Emiglia Romagna, dated 26 October See the press release of Banca d Italia, dated 26 October See the 2014 Annual Report of C.R.H. dated 26 March 2015, 70 See the press release of Liberbank, dated 26 October See press release of the Banco de España, dated 26 October See the 2015 Second Quarter Report of Liberbank, dated 3 August 2015, 15 PE

17 3. CONCLUSIONS The stated objectives of the Comprehensive Assessment were to: strengthen banks balance sheets by repairing the problems identified through the necessary remedial actions, enhance transparency by improving the quality of information available on the condition of the banks, build confidence by assuring all stakeholders that, on completion of the identified remedial actions, banks will be soundly capitalised. Were these objectives achieved? Strengthening banks balance sheets: Table 2 summarises the capital measures between January and September 2014, before announcement of the CA results, taken by the 25 banks. This includes capital raised, bonds converted and assets sold. The total amount is billion. 73 This is an important achievement and improves the safety of European banks although part of this amount was already required by restructuring plans agreed before the Comprehensive Assessment. Table 2: Capital raised before announcement of CA results by banks with a capital shortfall Bank Equity Issuance, CoCo conversions, asset sales [Mio EUR] Other measures Eurobank 2,864 Monte dei Paschi 5,000 National Bank of Greece 2,500 Banca Carige 799 Cooperative Central Bank 1,500 Banco Comercial Portugues 2,242 Veneto Banca 836 Banco Popolare 1, Banco Popolare di Milano Banco Popolare di Vicenza Piraeus Bank 1,750 Banco Popolare di Sondrio 343 Banco Popolare dell'emiglia Romagna 750 Credito Valtellinese Dexia 195 Hellenic Bank 70 1 Münchener Hypothekenbank 415 AXA Bank Europe 225 C.R.H. 240 Liberbank 640 Sum 23,259 1,265 Source: Summary of the present analysis, based on the press releases cited in the main text. 73 This number is higher than the billion of capital raised according to Table 1, second last column. The reason is that for banks in an approved restructuring plan the stress test was performed under the dynamic balance sheet assumption. Therefore some capital measures taken in 2014, but agreed earlier in a restructuring plan, are already reflected in the stress test outcome and do not or not fully count towards the second last column of Table 1. PE

18 Table 3 summarises the issuances of fresh capital on markets between November 2014 and July 2015, by the 25 banks. The total of 5.5 billion is considerably smaller than the 9.47 billion the ECB expected in total capital measures, see last column of Table 1. The reason is that banks partially executed capital measures other than equity issuance, such as asset sales, CoCo conversions, or regulatory capital requirement reductions. Table 3: Capital raised after announcement of CA results by banks with a capital shortfall Bank Equity Issuance [Mio EUR] Monte dei Paschi 2,993 Banca Carige 1,552 permenent tsb 500 Banco Comercial Portugues 304 Hellenic Bank 201 Sum 5,550 Source: Summary of the present analysis, based on the press releases cited in the main text. Furthermore, the necessity to raise new capital was reduced by an amount of billion resulting from other measures in Table 2. These other measures were still approved by the national Competent Authorities, mainly the Bank of Italy, before October Some of these measures, like the approval of certain internal risk models for some banks, or the removal of some add-on on capital requirements, reduced the capital requirements but did not involve any change in the financial situation of the bank. Strengthening transparency: The ECB and the EBA were largely transparent in the communication of the stress test method, although banks enjoyed a broad leeway, since they were allowed and encouraged to use their own internal models in working out the balance sheet implications of the macroeconomic scenarios. While these internal models were challenged by the ECB in the course of the Comprehensive Assessment, there is no public information available how the internal models applied by different banks looked like, and how far they differed from each other. This impairs transparency to some degree and threatens the level playing field. The results of the Comprehensive Assessment and the required consequences were fully communicated by the ECB. This is a major milestone. Unfortunately, after the publication of CA results the ECB never provided information to the public about the progress of capital measures. Such information was provided only by banks. A concluding statement by the ECB about the achievements of the measures following the Comprehensive Assessment is still wanting. Building confidence: Can stakeholders be assured that, on completion of the identified remedial actions, banks will be soundly capitalised? Certainly stakeholders know that the banks with capital shortfalls in the two prescribed scenarios hold more capital after the completion of the exercise. But it is open whether the banks now hold enough capital for other scenarios. As one example, consider the situation of Greek banks after completion of remedial action following the Comprehensive Assessment. At that stage they were not capitalised enough to withstand the actual events following in the Greek crisis of Summer Another 25 billion had to be mobilised by the European 17 PE