(When) should a non-euro country join the banking union?

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Paweł Smaga, PhD Warsaw School of Economics and National Bank of Poland (When) should a non-euro country join the banking union? Toward a Genuine Economic and Monetary Union OeNB Workshop in Vienna on September 10 and 11, 2015 This paper was co-authored by Ansgar Belke, Anna Dobrzańska and Daniel Gros The views expressed are those of the authors and do not represent those of the affiliated institutions.

Agenda 1. Introduction aim and scope of analysis 2. Potential benefits of opting-in 3. Potential risks of opting-in and possible remedies 4. Conclusions

1. Introduction aim and scope of analysis The option of opting-in to the banking union Non-euro area EU countries (focus on CEE) Attractiveness of opt-ing in the context of: o Robustness of national safety net, structure and stability of the national banking system vs o Assessment of banking union s construction Opt-in now or join the banking union upon euro adoption? Hitherto analyses: Berglöf et al. (2012), Darvas et al. (2013), Kisgergely and Szombati (2014) and IMF (2015) + country assessments

2. Potential benefits of opting-in Increased stability and confidence in the banking system Increase in quality of supervision and harmonization of supervisory practices o o Countering national bias/forbearance The ECB s reputation and credibility ( quality stamp ) Improved home-host relations o o Streamline communication and reduce/internalize coordination problems Access to parent bank supervisory data, chance to participate in JSTs

2. Potential benefits of opting-in Improved political position Some (limited) reduction of sovereign-bank nexus o Little room to maneuver in current regulatory framework Benefits for banks in opt-ins o Harmonized reporting and lower compliance costs o Centralized liquidity and capital management o Potentially lower funding costs, risk premia and higher ratings The SRM is a better solution than multiple national regimes o Addressing coordination and burden-sharing problems related to cross-border failures

3. Potential risks of opting-in and possible remedies Limited influence over decision-making process within the SSM o Supervisory Board Governing Council Remedy: Change in the TFEU? Lack access to backstops Remedy: Change in the TFEU and the ESM treaty? Direct recapitalization for all SSM banks? Swap lines between the opt-in NCBs and the ECB? The SSM might not be more efficient than national supervisor o Another, centralized supervisory layer + administrative burden o Operational effectiveness of task division within the SSM and the ECB Remedy: A sound and balanced cooperation framework in practice?

3. Potential risks of opting-in and possible remedies Too small to matter banks in opt-ins and centralized capital and liquidity management o Risk of dominance of home/group interests o No possibilities to resort to EBA binding mediation Remedy: Increased involvement of national supervisors? Prudent SSM policy of waivers for the application of prudential requirements? Complicated decision-making process of the SRM Remedy: Simplify the procedure and reduce number of parties involved?

3. Potential risks of opting-in and possible remedies The SRF is not mutualized from the start o A temporary problem Remedy: Increase the pace of mutualization or contributions? Bridge financing? Insufficient size of the SRF Remedy: Increase contributions? Pooling resolution and DGS funds? Lack of single deposit guarantee scheme Remedy: A fully fledged European Deposit Insurance Scheme with wellcapitalized single fund? Other risks o Opting-out is risky o Macroprudential policies of the ECB and national authorities

4. Conclusions Potential benefits, but more imminent risks unfavorable balance Different relative importance of benefits/risks among potential opt-ins Unequal treatment of opt-ins No quick fix remedies and changes in the treaties required Euro adoption mitigates the majority of risks for opt-ins Both benefits and risks of permanent opting-out A banking union for the euro area? First mover experience needed peer pressure?

4. Conclusions Opt-in decision depends i.a. on: o share of foreign ownership in banking system assets o size of the banking system and presence of SIFIs o condition of the banking system and crisis experience o supervisory standards o financial capacity of national resolution fund o perspective of euro adoption o political stance Non-euro zone countries assessments: o opting-out, wait-and-see, willing to opt-in Periodic reassessment of opt-in option warranted! SE, UK PL, CZ, HU RO, BU, DK

Thank you for the attention! Comments? More on banking union in: European Bank Restructuring During the Global Financial Crisis, Iwanicz-Drozdowska M. (eds.), Palgrave Macmillan, forthcoming 2015 contact: Paweł Smaga, PhD psmaga@sgh.waw.pl pawel.smaga@nbp.pl