Proportionality in banking regulation

Similar documents
Proportionality in regulation Brazilian experience. 18th Annual International Conference on Policy Challenges for the Financial Sector

FSI Insights on Proportionality Global Symposium on Development Financial Institutions

FSI Insights on policy implementation No 11

Basel Committee on Banking Supervision. Proportionality in bank regulation and supervision a survey on current practices

Basel Committee on Banking Supervision

Basel Committee on Banking Supervision. Fourteenth progress report on adoption of the Basel regulatory framework

Basel Committee on Banking Supervision. Ninth progress report on adoption of the Basel regulatory framework

Basel Committee on Banking Supervision

Basel Committee on Banking Supervision. Twelfth progress report on adoption of the Basel regulatory framework

EUROPEAN COMMISSION Directorate-General for Financial Stability, Financial Services and Capital Markets Union

BASEL III Basel Committee on Banking Supervision (BCBS)

Progress of Financial Regulatory Reforms

2016 Seminar for Senior Bank Supervisors from Emerging Economies. Implementation of Basel III Liquidity Requirements in Emerging Markets

Basel Committee on Banking Supervision

INTERNAL CAPITAL ADEQUACY ASSESSMENT PROCESS GUIDELINE. Nepal Rastra Bank Bank Supervision Department. August 2012 (updated July 2013)

Press release Press enquiries:

Isabelle Vaillant Director of Regulation. European Institute of Financial Regulation (EIFR) 23 Septembre 2016

SUPERVISORY POLICY STATEMENT (Class 1(1) and Class 1(2))

CRR II and CRD V: Basel IV implementation on European level

SAUDI ARABIA. Annex I: Banks

Supervisory Statement SS1/17 Supervising international banks: the PRA s approach to branch supervision liquidity reporting.

Basel Committee on Banking Supervision. Consultative Document. Pillar 3 disclosure requirements consolidated and enhanced framework

New package of banking reforms

Basel Committee on Banking Supervision. Regulatory Consistency Assessment Programme (RCAP) Assessment of Basel large exposures framework Brazil

Intraday Liquidity Monitoring Solution

Financial Stability Institute

COPYRIGHTED MATERIAL. Bank executives are in a difficult position. On the one hand their shareholders require an attractive

CRD 5: The new Large Exposures Framework February 2017

Key issues in Banking regulation. Investor meeting

Tailored to Small Markets: Implementation of Basel III Liquidity Requirements

prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/

This article is on Capital Adequacy Ratio and Basel Accord. It contains concepts like -

BCBS Standard for Interest Rate Risk in the Banking Book Objectives, Approaches and Disclosure

Banking regulation and supervision after the crisis where are we now, and what lies ahead?

Deutsche Bank s response to the Basel Committee on Banking Supervision consultative document on the Fundamental Review of the Trading Book.

Basel Committee on Banking Supervision

BASEL II & III IMPLEMENTATION FRAMEWORK. Gift Chirozva Chief Bank Examiner Bank Licensing, Supervision & Surveillance Reserve Bank of Zimbabwe

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL

Basel Committee on Banking Supervision. Progress report on Basel III implementation

Opinion of the European Banking Authority in response to the European Commission s Call for Advice on Investment Firms

The New DFSA Prudential Framework

The Bank of East Asia, Limited 東亞銀行有限公司. Banking Disclosure Statement

THE REVIEW OF INTERNATIONAL FINANCIAL REGULATION: Implications for Housing Finance in Emerging Market Economies

BERMUDA MONETARY AUTHORITY GUIDELINES ON STRESS TESTING FOR THE BERMUDA BANKING SECTOR

Additional Liquidity Monitoring Metrics

The Review of Solvency II. 01/02/2018 Hans De Cuyper, President of Assuralia

Basel Committee on Banking Supervision. Regulatory Consistency Assessment Programme (RCAP) Assessment of Basel NSFR regulations Brazil

Basel Committee on Banking Supervision. Consultative Document. Home-host information sharing for effective Basel II implementation

Secretariat of the Basel Committee on Banking Supervision. The New Basel Capital Accord: an explanatory note. January CEng

Basel II Briefing: Pillar 2 Preparations. Considerations on Pillar 2 for Subsidiary Banks

Basel Committee on Banking Supervision

Prudential supervisors and external auditors. Marc Pickeur, CBFA Brussels, 27 October

Addendum to the ECB Guide on options and discretions available in Union law

RE: Consultative Document, Simplified alternative to the standardised approach to market risk capital.

Capital Requirements Directive IV Framework Introduction to Regulatory Capital and Liquidity. Allen & Overy Client Briefing Paper 1 January 2014

GUIDANCE NOTE PILLAR 2 IN JERSEY

Introduction. Regulatory environment in Legal Context

Emerging from the Crisis Building a Stronger International Financial System

Importance of the oversight function for financial market infrastructures: General framework and objectives

WSBI s contribution to the Consultation of the Basel Committee on Microfinance activities and the Core Principles for Effective Banking Supervision

BERMUDA MONETARY AUTHORITY BASEL III FOR BERMUDA BANKS NOVEMBER 2017 RULE UPDATE

TRANSLATING REGULATORY CHANGE TO BALANCE SHEET ACTION

Course 14. Capital Adequacy

Regulation and Public Policies Basel III End Game

Commission services staff working document: Further possible changes to the Capital Requirement Directive (CRD4)

EBA FINAL draft Regulatory Technical Standards

Basel Amended Proposals on Capital and Liquidity Requirements

DFSA OUTREACH SESSION Prudential Supervision 25 June 2018

Hot Topic. Major changes announced for the European prudential regime for investment firms

Liquidity Risk Supervision of Large Banking Organizations

BERMUDA MONETARY AUTHORITY

Liquidity Risk Management. Thomas Schmale, Solution Management Analytical Banking, SAP AG, 29 th May 2014

Chapter 3 BASEL III IMPLEMENTATION: CHALLENGES AND OPPORTUNITIES IN CAMBODIA. By Ban Lim 1

E.ON General Statement to Margin requirements for non-centrally-cleared derivatives

Basel Committee on Banking Supervision. Liquidity coverage ratio disclosure standards

CONSULTATION PAPER NO.114

Introduction and legal basis. EBA/Op/2017/ December 2017

Secure Trust Bank PLC. Pillar 3 disclosures for the period ended 30 June 2018

ECB Guide to the internal liquidity adequacy assessment process (ILAAP)

2017 Seminar for Senior Bank Supervisors from Emerging Economies. Implementation of Basel III Liquidity Requirements in Emerging Markets

Feedback statement. Responses to the public consultation on a draft Guideline and Recommendation of the European Central Bank

OTC Derivatives Market Reforms. Third Progress Report on Implementation

MEMO N 04 THE BASEL ACCORDS AND THEIR CONSEQUENCES FOR THE ECONOMY

Basel Committee on Banking Supervision. Basel III counterparty credit risk - Frequently asked questions

Proportionality Principle: Its Application & Challenges. Damodaran Krishnamurti Oct 2018

Basel II Pillar II Practice Study The World Bank By Ana María Avilés

Introduction and legal basis. EBA/Op/2014/ October 2014

GUIDELINES FOR THE INTERNAL CAPITAL ADEQUACY ASSESSMENT PROCESS FOR LICENSEES

EACB Comments on the Consultative Document of the Basel Committee on Banking Supervision. Fundamental review of the trading book: outstanding issues

EBA/CP/2015/ November Consultation Paper

EBA/GL/2017/15 14/11/2017. Final Report

Financial Reforms: Completing the Job and Looking Ahead

RCAP jurisdictional assessments: self-reporting monitoring template for RCAP follow-up actions

Deutsche Bank. Pillar 3 Report as of March 31, 2018

Financial Stability Institute

Guidance Note: Stress Testing Credit Unions with Assets Greater than $500 million. May Ce document est également disponible en français.

Basel Committee on Banking Supervision. Report to G20 Finance Ministers and Central Bank Governors on Basel III implementation

Samba Financial Group Basel III - Pillar 3 Disclosure Report. September 2017 PUBLIC

INTERNAL CAPITAL TARGET GUIDELINE ANNEX Summary of Consultation Comments and Financial Institutions Commission (FICOM) Responses

ECB Guide to the internal capital adequacy assessment process (ICAAP)

Transcription:

Proportionality in banking regulation Brussels, Belgium 7 March 2018 Fernando Restoy, Chairman *The views expressed in this presentation are those of the presenter and not of the BIS or the Basel-based committees. Restricted

Overview 1. The concept 2. The (declared) objectives 3. Proportionality and level playing field 3.1 Rationale 3.2 Constraints 4. The modalities 4.1 Existing proportionality regimes 4.2 Main features 5. Considerations Restricted 2

1. The concept Minimise regulatory intervention required to achieve policy objectives Regulation vs supervision In regulation: about tailoring requirements to avoid unnecessary complexity leading to excessive compliance costs for firms In supervision: about adjusting supervisory intensity based on risk profile to avoid excessive costs for supervisors. Both concepts are independent. Mistake to consider them either complementary or substitutes. Restricted 3

2. The (declared) objectives 1. Economic: Facilitate a level-playing competitive field 2. Prudential: Avoid excessive concentration around few large banks. 3. Political: Small banks play a social role (facilitate development of local economies) Restricted 4

2. The objectives (cont) The economic (competitive) motivation is probably more robust than the prudential and the political objectives: Small banks fail more frequently than large banks Some failures of small banks may generate systemic implications Other means (rather than alleviating prudential requirements for small firms) to cope with too-big-to-fail issues No strong evidence of a link between size and number of banks and access to credit (eg different banking structures in Europe). Restricted 5

3. Proportionality and level playing field 3.1 Rationale: Basel principles are complex Complexity justified for rules to cope with risk generated by large-complex-international banks Complexity implies additional compliance costs which are disproportionately high for small institutions Therefore: small banks are unduly penalised Restricted 6

3. Proportionality and level playing field (cont) 3.2 Constraints: Keep resilience of all institutions Do not overprotect small institutions from competitive forces. Mind overcapacity and impact of technology on optimal size and optimal market structure Do we have too many banks in Europe? Restricted 7

4. The modalities 4.1 Existing proportionality regimes: Starting point: Proportionality already embedded in Basel III (see Annex 1) Standardised methods provide simplicity (but not reduced stringency) Beyond Basel III: Additional proportionality envisaged in a number of jurisdictions (see FSI Insights #1 and Annex 2) Restricted 8

4. The modalities (cont) 4.2 Main features: Standards: Standards: Liquidity (LCR, NSFR), Counterparty risk, large exposures, market risk Pillar 2 / SREP / ST Reporting and disclosure requirements Discrimination metrics Size (how small is small?) Other criteria Two approaches (see FSI Insights #1 and Annex 3) Categorisation approach Specific standard approach Restricted 9

5. Considerations Alleviation of some requirements may not be prudentially irrelevant: eg reporting, SREP and liquidity requirements SSA (Specific Standard Approach) allow fine tuning: reasonable thresholds to exempt from FRTB or Counterparty credit risk may not be the same as for reporting requirements, STs or liquidity CA (Categorisation Approach) provides clarity and consistency with risk-based supervision and resolution strategies. Weighing economic objectives and constraints (ie competitive and prudential considerations) a moderate proportionality regime based on SSA seems prudent. An alternative could be Categorisation Approach for proportionality with different capital add-ons per category. Restricted 10

Annex 1: Proportionality is embedded in Basel III Source: BCBS and FSI. Restricted 11

Annex 2: FSI Insights No 1: Proportionality in banking regulation: a cross-country comparison (August 2017) Targeted issues for proportionality Table 3 Issues Brazil European Union Hong Kong SAR Japan Switzerland United States Liquidity regulation (LCR and NSFR) Yes Yes Yes Yes Yes Yes Counterparty credit risk Yes* Yes* Yes No Yes Yes Large exposures framework Yes* Yes Yes* No Yes Yes* Credit risk Yes* No Yes No Yes Yes Market risk Yes* Yes Yes Yes Yes Yes Minimum capital ratios No No No Yes No No Interest rate risk in the banking book Capital planning and supervisory review** Yes* Yes No No Yes* Yes Yes Yes No Yes Yes Yes Disclosure requirements Yes* Yes* Yes No Yes Yes Recovery plan Yes Yes Yes Yes Yes Yes *expected; **including stress testing Colour code: purple: Pillar 1 elements, beige: Pillar 2 elements, blue: Pillar 3, brown: other. Source: National regulation (see Annex); table collated by the FSI. Restricted 12

Annex 3: FSI Insights No 1: Proportionality in banking regulation: a cross-country comparison (August 2017) Examples of proportionality strategies Table 1 Categorisation approach (CAP) Specific standard approach (SSAP) Classification of banks Brazil Five categories European Union Japan Two categories Hong Kong SAR Switzerland Five categories United States Sources: National data (see Annex); table collated by the FSI. Exceptions in following areas - Trading book - Disclosure - CCR - Large exposures - Credit risk - Liquidity framework - Large exposures - Advanced approaches - Counterparty credit risk - Stress tests and capital planning - Trading book - Liquidity framework Restricted 13