CRD Amendments. Referring to Large Exposures we consider the proposal as significantly critical especially in context of liquidity aspects.

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1 189/Dr.Rudorfer/Br CRD Amendments The Bank and Insurance Division of the Austrian Federal Economic Chamber representing the entire Austrian Credit Industry would like to comment on the EU Commission s proposal on the CRD amendments as follows: Referring to Large Exposures we consider the proposal as significantly critical especially in context of liquidity aspects. A. Large Exposures: 1) Art. 111 Interbank Exposures: We advocate retention of term-based weighting regulations for interbank exposures for the following reasons: The main issue in the current financial crisis is the lack of liquidity caused by a lack of trust among credit institutions (and not by losses). If interbank deposits are restricted as planned, a further lack of liquidity at the expense of all types of credit institutions would result. A deletion at this stage in particular would send the wrong signal, as it would in all likelihood result in a lack of liquidity, which in fact the central banks are currently seeking to rectify. This could also be interpreted as an unreasonable restriction of the freedom of capital movement. Without a real impact study regarding the effects on the interbank market we run the risk of giving the wrong incentives, as said problems were caused by large exposures among credit institutions. In particular, the debate should also pay attention to the issuers point of view and their liquidity control, which would ultimately also be affected by this LE regulation: It is necessary to point out, for instance, that issuers do not want to see any unreasonable burden on desirable long-term liquidity. Differences in the issuers refinancing structures should also be taken into account. In their refinancing, credit institutions would be compelled to discontinue their relations with investors who are no longer able to invest due to the new rules; it would then be debatable whether a sufficient number of alternative refinancing partners will always be available, thus further reducing refinancing recourses.

2 The envisaged rules could prompt the interbank market to stop granting uncommissioned interbank lines without service provision fees and without any legal claim as is custom today (and hence without capital requirement in solvency). The reason is that institutions would no longer be able to count on being able to draw on uncommissioned interbank lines to the previous extent as the number of counterparties would be limited. To ensure refinancing reliability none the less, they could enter into legal framework agreements with their refinancing partners, i.e. take out commissioned lines of credit. On the one hand, the provider of yet undrawn line of credit would then be required to provide capital backing (except in case of terminability at any time or in case of a downgrading of the rating: in IRB CCF of 75% - Sec. 65 (9) no. 3 SolvaV - or in CRSA CCF on 20% when due within 1 year); within the LE, a CCF of 100% would be applicable in any event and the provider would receive the commitment fee. This would lead to a further shortage, as previously uncommissioned lines of credit would be converted into commissioned ones and would have to be fully added to the overall exposure. On the other hand, it would also result in a dramatic cost increase on the interbank market, since, unlike before, commitment fees would now be taken. This affects large groups of banks in particular, as they form a larger group of related clients (which had been irrelevant in the money market so far due to the zero weighting) and their refinancing partners reach the 25% limit more quickly. We also see a major problem in refinancing with currencies in small currency areas, in particular with regard to CEE currencies: here, the number of refinancing partners is limited by the nature of things and refinancing partners are not particularly large and/or do not have large equity. Introducing the rules under review could restrict subsidiaries in CEE in their business activities due to a lack of alternative refinancing partners - which would have to be found due to the proposed rules. The effect of such restrictions on the money market of these countries or their currencies could cause them to be subject to unforeseeable consequences for their national economies and economic development. We also see a problem with regard to the issuing of eligible collaterals by banks. If all interbank exposures and off-balance-sheet items, short- and long-term financing were added up, potential investors in such collaterals could be compelled to prefer eligible products from other issuers, in particular from central governments, who need investors for their refinancing to avoid hitting the 25% limit. On the other hand, this would make it more difficult and expensive to take out long-term refinancing in the course of such issues. This effect must be avoided in any event. In connection with the impact on the refinancing of banks we demand that balance-sheet netting as well as netting master agreements for pension transactions and commodities or securities borrowing or lending transactions Page 2/15

3 also be recognised in the LE in any event with a minimising effect on credit risk. Please also see the comment on CRM. Finally, the effects on the refinancing term structure must be addressed: it is not clear from today s point of view what impact the new rules will have on the terms structure and term transformation of credit institutions. In any event, this would have to be studied in depth to avoid undesirable effects. We believe that, in particular, the combination of abolishing the existing weighting provisions for undrawn credit lines and for interbank exposures is unsustainable. Short-term claims in the interbank area, in particular, must be zeroweighted to achieve adequte liquidity (Li) control. Specific complex transactions are possible only with specific counterparts (e.g., securities lending transactions). Accordingly, if the 25% limit is exceeded for such counterparts, additional transactions become impossible in the absence of suitable alternative counterparts. The paradigm change of the borrower s creditworthiness in the short-term interbank business (criterion for the lender s internal allocation of limits) to the lender s capital resources in combination with the requirement to form groups of related clients would further aggravate the refinancing situation particularly for large groups of banks. The current preferential treatment of interbank transactions is justified in view of the strict solvency and liquidity supervision of credit institutions (the contingency risk is much lower than in the case of other borrowers). The envisaged restriction would also lead to further increases in refinancing costs. Apart from the liquidity reserve (Art. 113 (3) (n) CRD) at least the minimum reserve held by an intermediary as defined in Art. 10 Regulation 1745/2003 should be exempted (cf. in solvency: Annex VI, Part 1 No. 40 CRD). Art. 111 (1) (i): With regard to the 25% limit for large exposures (LE) in the interbank area, we would at least have to ensure the zero-weighting of exposures due within a year for short-terms claims in the Interbank area. Discharge of claims related to the issuer s liquidity control: eligible bank issues should generally be excluded from being credited to LE. Balance-sheet netting as well as netting master agreements for pension transactions and commodities Page 3/15

4 or securities borrowing or lending transactions would have to be deemed as minimising the credit risk in LE. Please also see the comment on CRM in the LE. If an absolute amount is specified here, this would have to be at least EUR 300 million in order to mitigate the problems of small- and medium-sized credit institutions. This limit would also have to be valorised accordingly. Retention of zero-weighting for liquidity reserve and minimum reserve: This measure contributes significantly to meaningful capital control in decentralised structures and hence to stability within such structures, as has already been shown in the past. Abolishing it would lead to instability. In addition, the minimum reserve held by an intermediary should also be zeroweighted. Please also see the arguments below. Art. 111 (1) (ii): Introducing an absolute amount as an additional limit for large bank exposures (LE) is no adequate substitute for abolishing the zero-weighting in the shortterm interbank area. In light of the efforts to reduce national discretionary rights, we are against the proposed discretionary right. The proposal in Art. 111 (1) (ii) with regard to LE with institutional involvement appears to be too complex an approach. We advocate a simplification that would be easier to implement. We expressly support deletion of the LE limitations of 800% and 20% in Art. 111 (2) to (3). Art. 112 (4): In paragraph 4 of Art. 112 we request clarification of the reference phrase "unless permitted under Article 115". Art. 115 contains a special rule for exposures guaranteed by mortgages, the collateral of Annex VIII, Part 1 Points 20 and 21, which are not recognised for LE purposes, refers to completely different collateral (receivables, other physical collateral), and the reference to the mortgages (Art. 115) is unclear. Art. 113 (1) (e): Exposures to third countries in national currencies should continue to be assigned a 0% risk weight, particularly if such exposures are based on national legislation (retaining Art. 113 (3) (e)). This requirement to refinance in national currencies would exclude the currency risk. In practice there would also be no transfer risk, since this Page 4/15

5 requirement is met only within local markets and not in case of cross-border activities. If Art. 113 (3) (e) CRD were deleted, at least the required minimum reserve should be exempted from the support requirement unchanged to avoid violations of the law by the CI group due to national legal provisions. If the privileged 0% risk weight is abolished for additional exposures in national currency, we advocate a weighting of 20%. The discretionary right of assigning a weighting of 20%, which previously had been provided for in Art. 115 for large exposures with a risk weight of 20% in solvency, will be abolished; Art. 113 (1) (e) covers only exposures with a 0% risk weight. This is problematic insofar as regional authorities which fail to meet the requirements for zero weighting in terms of solvency but are assigned a 20% risk weight in solvency must be assigned a 100% risk weight in the LE. 2) Intra-Group Exposures Art. 113 (1) (f): The Austrian credit services sector advocates a modified retention of Art. 113 (2) insofar as the discretionary right becomes a mandatory provision ( shall instead of may ). The exemption in Art. 80 (7) is too restrictive, as exposures are expressly excluded. The reason for this is that CI groups (like corporate associations - cf. below re. Art. 113 (3) (n) CRD) due to their internal structures are effectively protected against external crises, but such stabilising structures become possible only through participations. In the view held by decentralised sectors, institutional security systems as set forth in Art. 80 (8) should also be included in the zero weighting. A 0% risk weight should furthermore be assigned to all equity exposures, which currently are exempted by virtue of paragraph 8. 3) Zero weighting for exposures to central institutions Art. 113 (3) (n) CRD The following arguments, in particular, argue against a deletion of the zero weightings for central institutions: The EU would easily break up a perfectly functioning system, thus causing further disturbances on the financial markets. Page 5/15

6 Art. 113 (3) (n) CRD was created deliberately as a privilege for liquidity equalisation so typical of the decentralised sectors. Such privilege applies in case of a contractual or statutory requirement of liquidity equalisation. This is a requirement met by all decentralised sectors in the EU, as liquidity equalisation traditionally constitutes the founding mandate of all central institutions. In this context, it must be noted that decentralised sectors also contribute significantly to the stability of financial markets. This is important, particularly since the provision of financial services to small- and medium sized companies and retail clients is ensured by regional banks. Moreover, the call for retention of Art. 113 (3) (n) (for decentralised sectors) corresponds to the call for retention of Art. 113 (2) CRD (for majority stakes in the CI group). Cf. the arguments already made in Art. 113 (2) CRD, i.e. that the zero weighting, which should be retained, also includes equity interests. Furthermore, under IFRS, shares in unconsolidated companies are to be valued at their fair market value. This could have the result that without expending the assets of investing bank, the central institution s value would exceed the limit of EUR 150 million, and the participation would have to be sold at least in part. We also need to stress that the decentralised sectors have hedging mechanisms for client funds in place which clearly exceed the statutory deposit guarantees (crossguarantee systems, mutual support groups). It is therefore absolutely necessary to maintain the zero weighting of Art. 113 (3) (n) CRD in order to be able to continue the established and recognised intrasectoral systems of liquidity equalisation in decentralised banking sectors. Solution through Art. 80 (8) CRD - no suitable alternative The proposed alternative solution for Art. 80 (8) CRD (intra-group exposures) is not a suitable alternative. This is due to the fact that it requires an institutional guarantee. For this reason, not all decentralised sectors are able apply Art. 80 (8) CRD. All decentralised sectors, however, have liquidity equalisation systems in place which meet the requirements of Art. 113 (3) (n) CRD. In addition, compliance with Art. 80 (8) CRD is monitored by the national regulatory authorities. However, Art. 80 (8) CRD (or its implementation in Sec. 22a (9) Austrian Banking Act) includes a comprehensive list of criteria that need to be met. If the regulatory authorities find that even a single one of these criteria is no longer met, the permit could be withdrawn. A decentralised sector would be at the mercy of this factor without any further safety net. The consequence in turn would be that the established and Page 6/15

7 recognised intra-sectoral liquidity equalisation in decentralised banking sectors would no longer function. 4) Further aspects Art. 106 (1): We suggest clarification on whether "exposure" means the value prior to application of credit risk mitigation (CRM under Art. 114 and 115) and whether it is identical with Art. 110 (1) sub-para. b). Art. 108: It would need to be clarified that "value" means the value determined in accordance with Art. 110 (1) sub-para. b) (i.e. prior to application of CRM under Art. 114 and 155). Art. 110 (1) final paragraph: We request clarification on why a consolidated report on the 20 largest exposures will be required for IRB credit institutions (CI). If the 20 largest exposures are also (as must be assumed) large exposures (LE), which must be reported as already specified under Art. 110 (2), we ask ourselves what the purpose of this additional report is. Art. 110 (3): While the content of this provision is serviceable, it s implementation is difficult. The minimum requirement raises concerns that implementation of paragraph 3 in Member States would vary greatly with regard to the extent of supervision. Credit risk mitigation (CRM) We expressly welcome the clear improvement that the current draft constitutes compared to previous drafts. We support the Commission s proposal to open up the use of CRM techniques for large exposures to all banks in general, and in particular also to standard approach banks, FIRB banks and to banks not using the financial collateral comprehensive method. The recognition of real estate collateral is judged positively. It would be desirable to extend this to other physical collateral and specifically excluded exposures. The simple and comprehensive collateral approach should be available for financial collateral as well, to avoid any disadvantages to smaller institutions. Page 7/15

8 Specifically, we would like to point out the following issues: Value E* in Art 114 (1) refers exclusively to Annex VIII, Part 3, Point 33, which in turn reflects the fully adjusted claim value after volatility adjustment and deduction of the value of financial collateral, which is used as part of the financial collateral comprehensive method. In addition to the above, we must note, on the one hand, that all collateral treated not in accordance with this method ( unfunded credit protection and financial collateral simple method) but in accordance with the substitution method, in particular personal collateral but also financial collateral, appears to be excluded if the simple method is used, as no fully adjusted claims value is calculated. On the other hand, the final clause of Art. 117 (1) states that both the financial collateral comprehensive method and the simple method may be used for purposes of Art. 117 (1). We request clarification that under Art. 114 (1) only the financial collateral comprehensive method and under Art. 117 (1) (b) only the financial collateral simple method can be used; the discretionary right here should depend on the provisions set forth in the CRM. Re. Art. 115: Even though the recognition of real estate collateral is considered to be a very positive development, we do suggest the use of an approach analogous to solvency for reasons of expenditure and clarity. o A new collateral regime will be introduced, which conforms neither to that in the standard approach (CRSA) (Annex VI, Part 1, Points 51 to 60) nor to that in Annex VIII, Part 3, Points 62 to 72 (modification of LGDs in FIRB) nor to the alternative approach in Points 73 to 75 (in FIRB), but diverges from the above. o An annual valuation of residential real estate is not in line with the standard in the solvency regime, which provides for a review of the collateral s value every three years; statistical methods may also be applied (cf. Annex VIII, Part 2, Point (b)). Similarly, Art. 115 as it does not include any reference to the relatively complex methods as part of credit risk minimising techniques raises a number of unresolved issues, which remain unanswered, but which should be clarified by the legislator for reasons of legal security: e.g., Is the use of statistical procedures permitted? Requirements of the valuers independence? Crediting of senior liens? What does up to mean? Which valuation rates should be applied: market value or collateral value method? o We suggest that CIs use the same method for the purposes of Art. 111 (1) as for solvency purposes. It does not seem justified Page 8/15

9 that one should not be able to rely on this method for LE purposes. It also does not appear justified to introduce a new regime for LE purposes if highly developed systems already exist as part of credit-risk minimising techniques. Even if the objective is to set up a simple model for LE purposes, it would be easier still to simply recognise the already implemented and applied methods as part of credit-risk minimisation. This would also be in line with the stated objectives of realising an alignment with solvency. The CI s additional administrative expenses would be kept to a minimum without an increase in regulatory risks. With regard to CIs that do not apply the AIRB approach, Arts. 114 to 117 should legally ensure the following: o Recognition of balance sheet nettings for LE purposes, unless already included in Art. 113 (1) (h). o Recognition of master netting agreements on pension transactions, commodities or securities borrowing transactions, and other capital market transactions (is - in our opinion currently not addressed at all, but as noted above would be absolutely necessary, particularly with regard to changes in interbank exposures). o Recognition of financial collateral as part of the simple (substitution method) (clarification that Art. 117 (1) (b) is meant that way), and the comprehensive method (fully adjusted exposure value E*) (clarification that Art. 114 (1) is meant that way), here with or without own valuation of haircuts. o Recognition of real estate collateral (change in Art. 115 with regard to the comments made above): for CRSA banks: recognition of the risk weight approaches in Annex VI, Part 1, Points 51 to 60; for FIRB banks: Annex VIII, Part 3, Points 62 to 72 (modification of LGDs in FIRB); approach in Points 73 to 75 (alternative method in FIRB) o Recognition of other credit protection in accordance with Annex VIII, Part 1, Point 23 to 25 (life insurance policies, deposits with third party institutions, repurchsable instruments issued by Page 9/15

10 third party institutions) (has not been taken into account at all so far, but is also recognised by Art. 112 (4); o Recognition of personal collateral as part of the substitution principle, which is also applied in the LE (here: third party attribution ): guarantees, sureties, surety programs, credit derivatives, cumulative assumption of debts, etc. (clarification that Art. 117 (1) (a) is meant that way). For banks applying AIRB: recognition of LGD/PD modifications in solvency by all collateral, not only with regard to financial collateral (Art. 114 (2)) (currently, Art. 114 (2) exclusively addresses financial collateral). Art. 114 (1): In addition to the reference to Art. 111 (1) (calculation of exposure values), a reference to Art. 110 (1) sub-para. d) (reporting of exposure values under CRM) should be included. Art. 117 (1) (b) final clause: A mismatch of term and collateral under the comprehensive method should not result in an exclusion of this approach, but should be regulated through haircuts. Netting The option of netting should be provided in any event for measuring the 25%-limit or the limit amount (EUR 150 million) in any event regardless of the position in principle (not clear in the directive text). Credit Conversion Factors - CCF We advocate implementation of the CCF provisions in the large exposures (LE) regime for the following reasons: The CCF approach serves to illustrate the current probability of the utilisation amount at a future point of default in respect of any not yet utilised line of credit. We do not see any reason why these assumptions should not apply to the large exposures regime as well. In any event, a general weighting of 100% does not reflect the actual risk. The proposed changes in connection with the calculation of the effects of minimising the credit risk and a general 100% support of off-balance sheet transaction (= high credit risk) are not comprehensible, since this new approach distorts the credit risk. Classification of off-balance sheet items in the standardised approach and/or the IRB approach should as before be based on the underlying credit risk (low, medium/low, medium, high). Page 10/15

11 The currently existing national discretionary rights should be retained (STA, F- IRB) or A-IRB banks should be allowed to use their own CCF-estimates (analogous to solvency). B. HYBRID CAPITAL INSTRUMENTS We welcome that some comments made by the credit services sector have been heeded and believe that they will enhance the practical usability of this instrument. Art. 57 (a): We have learned that Art. 57 (a) is once again to be revised as follows: (a) capital within the meaning of Article 22 of Directive 86/635/EEC, in so far as it has been paid up, plus the related share premium accounts, it fully absorbs losses in going concern situations, and in the event of the bankruptcy or liquidation of the credit institution, it ranks after all other exposures but excluding cumulative preferential shares; With regard to the above, we would like to specifically and generally point out the following: "plus the related share premium accounts" should be included either at the end or before "in so far", since otherwise the remaining conditions which also refer to "in so far" are no longer comprehensible. "in so far as it has been paid up" is a slight tightening of the current provision, which in Art. 22 RL 86/635/EEC refers to "subscribed capital". However, it is not of particular practical relevance, since it already follows from Art. 61 (2) that capital must be available; this is not the case with capital that has only be subscribed. Still, "paid up" should be avoided. It is not about payment (as is the case in Sec. 23 (3) Austrian Banking Act), but performance. Performance may be effected by way of contributions in kind or, for instance, in case of a nominal capital increase by simply transferring reserves to nominal capital. Accordingly, instead of "paid up", e.g. the term "effected" should be used. "other" in "it ranks after all other exposures" suggests that the core capital provider is also creditor. If he indeed were creditor as well and would have to be subordinated to all other claimants, the revision would merely constitute a rewording of the first amendment proposal, since subordination to all other claimants indeed means "most subordinated". This should be expressed by deleting the word "other". Page 11/15

12 Art. 66 (1a) (a) CRD In accordance with Art. 63a (a), the proposed rules require the approval of the competent supervisory authority prior to amortisation or termination of hybrid capital. This measure should suffice to significantly dispel all major concerns against hybrid capital it is no longer possible for a bank to easily amortise its hybrid capital and thus reduce the safety buffer. The objective of the amendment to the directive is the implementation of the Sydney Press Release (SPR). Under the predominant interpretation, the wording of the press release allows only for hybrid capital of up to 50%. In light of the supervisory control of hybrid capital repayments and of the SPR s margin, a scope of 50% in Art. 66 (1a) (b) instead of the currently provided 35% seems adequate for hybrid capital. The argument in favour of such increased limits is to be found not so much in lower capital expenditure for credit transactions (but could be up to 10 base points), but rather in the required higher flexibility of capital management in the surrounds of variable and pro-cyclical capital requirements. Hybrid capital is crucial so as to be able to take out capital during economic downturns, which can be repaid in more relaxed times upon relevant regulatory approval without causing additional unnecessary and potentially substantial costs. regarding specific issues: (i) We welcome the concept in principle. It should be clear, however, that a write-down should not be established as a criterion using the backdoor of regulatory approval relevant concerns have already been expressed in earlier comments (makes instruments more expensive and less attractive, absence of a write-down is in line with international requirements). (ii) We welcome this. (iii) The requirement of compliance with capital rules or the requirement of regulatory approvals prior to terminations of hybrid capital increases the security of this instrument for the bank s creditors. From the risks aspect, further restrictions therefore do not appear necessary and from an economic point view not desirable. C. WAIVERS FOR COOPERATIVE BANK NETWORKS AND OTHER TECHNICAL AMENDMENTS Art. 87 (CIUs): Page 12/15

13 We support the Commission s initiative to revise Art. 87 CRD, especially since, without an amendment to Art. 87 (11) and (12) CRD, exposure funds of IRBA banks would be discriminated. Also from the aspect of better regulation, in particular the look-through approach of Art. 87 (11) CRD is disproportionate and together with the provision of Art. 87 (12) CRD results in an exorbitantly high equity requirement for exposure funds as compared to direct exposures. To comply with the original intention, i.e. to realise a look-through approach in Art. 87 CRD, which treats exposure funds like direct exposures, the de facto fallback variants of Art. 87 (11) and (12) CRD would have to be adjusted, since otherwise they would have to be resorted to again and again for alack of alternatives. The following premises are essential for a review of the look-through approach of Art. 87 CRD: a) in principle look-through is a task for the investment company, since the investment company and/or the depot bank have/has the portfolio s data and any third party would hence be more likely than ever to resort to the investment company. This would lead to clearer handling and facilitation of management. b) Currently, the look-through calculation is based on individual internal rating systems of the investing bank. This requirement is impracticable and not in line with market reality, since one investment company definitely could have several IRBA banks as investors, for instance, which in turn each have their own individual internal rating system. It is thus necessary to standardise the look-through approach so that the method is equally applied to all IRBA investors. In this context we would like to refer to Annex VIII, Points and , which also reflect the look-through approach. As the relevant requirements for shares in exposure funds are too restrictive, however, since the fund s portfolio could change, we would request to change the diction to partly eligible. Art. 95 (2): It is not comprehensible why a (minimum) floor of 15% of the risk-weighted exposure amounts of the guaranteed pool is included. Calculation of the exposure amounts of (retained) guarantee items does in principle follow from the provisions in Annex IX; it might indeed be possible that an originator does not retain any guarantee items or only to any extent that will lead to a lower risk-weighted exposure amount. The introduction of a floor is thus inefficient and "punishes" originators seeking to maximise their RWA relief. Significant expenses for technical modifications are an additional consequence. Page 13/15

14 D. TECHNICAL AMENDMENTS TO DIRECTIVE 2006/48/EC Art. 89 (1) (t) (d) (extension of permanent partial use regarding exposures to other Member States): We expressly support this change. Changes in Annex VI, Part 1, Points 29, 31 and 73 (clarification with regard to short-term claims in CRSA): We expressly support this change. Changes in Annex VII, Part 1, Point 25 (clarification within the internal investment model): We expressly support this change. Changes in Annex VII, Part 4, Point 96 (expansion of the recognition of in collateral providers in AIRB): We expressly support this change. Changes in Annex VIII, Part 1, Points 9 and 11 (partial recognition of CIUs as part of CRM): We expressly support this change. Changes in Annex VIII, Part 2, Point 13 (changes to the requirements for a recognition of life insurance policies in CRM): We expressly support this change. Changes in Annex VIII, Part 2, Point 16 (recognition of claims with counterguarantees by international organisations with a CRSA-RW share of zero): We expressly support this change. Changes in Annex VIII, Part 3, Point 24 (changes with regard to the partial application of the simple or comprehensive method for financial collateral in the event of temporary or permanent partial use): We expressly support this change. Changes in Annex VIII (changes with regard to clarification of the order of CCF and CRM): We expressly support this change. In this connection it would be desirable to clarify that the collateral provider s respective CCF would be applied if the substitution principle is applied (in particular as part of personal collateral). In case of IRB banks, the relevant CCF application may show discrepancies due to application of a temporary or permanent partial use. Yours sincerely Page 14/15

15 Dr. Herbert Pichler Managing Director Division Bank & Insurance Austrian Federal Economic Chamber Page 15/15