ABI Response to EBA Discussion Paper On Defining Liquid Assets in the LCR under the draft CRR

Similar documents
European Association of Co-operative Banks Groupement Européen des Banques Coopératives Europäische Vereinigung der Genossenschaftsbanken


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

The Use of IFRS for Prudential and Regulatory Purposes

Response to discussion paper of the Basel Committee on the regulatory treatment of sovereign exposures

COMMISSION DELEGATED REGULATION (EU) No /.. of XXX

Opinion Draft Regulatory Technical Standard on criteria for establishing when an activity is to be considered ancillary to the main business

Opinion of the EBA on Good Practices for ETF Risk Management

CONSULTATION PAPER ON DRAFT RTS ON TREATMENT OF CLEARING MEMBERS' EXPOSURES TO CLIENTS EBA/CP/2014/ February Consultation Paper

Warsaw, 19 December European Banking Authority

Content. International and legal framework Mandate Structure of the draft RTS References Annex

Consultation Paper. Draft Regulatory Technical Standards

Non-paper on K-factors for Risk to Market (RtM) from NL and CZ. Introduction

Guidelines on credit institutions credit risk management practices and accounting for expected credit losses

Final Draft Regulatory Technical Standards

EBA/GL/2013/ Guidelines

COMMISSION DELEGATED REGULATION (EU) /.. of XXX

EBF Response to the EBA Consultations on currencies with constrained availability of Liquid Assets

BVI position on IOSCO s Consultation Report on Good Practices on Reducing Reliance on CRAs in asset management Reference: CR04/14

ANNEX 4 MAIN DOCUMENTS PUBLISHED 1 BY THE INTERNATIONAL SUPERVISORY FORA: FSB, BCBS, EBA, ESRB AND ECB IN THE FRAMEWORK OF FINANCIAL STABILITY

Citigroup Global Markets Limited Pillar 3 Disclosures

(Non-legislative acts) REGULATIONS

Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures

Regulations and guidelines 4/2018

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL

COMMISSION DELEGATED REGULATION (EU) /... of

BVI comments regarding ESMA s call for evidence Competition, choice and conflict of interest in the credit rating industry Ref.

Consultation Paper. Draft Guidelines On Significant Credit Risk Transfer relating to Article 243 and Article 244 of Regulation 575/2013

Managing liquidity risk in a changed and global world

ESMA CONTRIBUTION TO THE EBA S DRAFT REGULATORY TECHNICAL STANDARDS ON CAPITAL REQUIREMENTS FOR CCPs

Re: European Banking Authority Consultation on the Guidelines on stress testing and supervisory stress testing (EBA/CP/2015/28)

Basel II: Requirements for European Integration Kangaroo Group Brussels, 6 October 2004

26 June 2014 EBA/CP/2014/10. Consultation Paper

ICAAP Q Saxo Bank A/S Saxo Bank Group

EBF response to the BCBS consultation on the revision to the Basel III leverage ratio framework. 1- General comments. Ref: EBF_ OT

EBA REPORT ON RESULTS FROM THE SECOND EBA IMPACT ASSESSMENT OF IFRS July 2017

Final Draft Regulatory Technical Standards

12th February, The European Banking Authority One Canada Square (Floor 46), Canary Wharf London E14 5AA - United Kingdom

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

ESMA Risk Assessment Work Programme 2018

Mapping of Spread Research credit assessments under the Standardised Approach

COMMISSION DELEGATED REGULATION (EU) /... of

Final Report. Amendments to the EMIR Clearing Obligation under the Securitisation Regulation. 12 December 2018 JC

ESMA Risk Assessment Work Programme 2019

EU Financial Services Legislative agenda An Update

Comments. Register of Interest Representatives Identification number in the register:

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

Consultation Paper. Amendments to the EMIR Clearing Obligation under the Securitisation Regulation. 04 May 2018 JC

Capital Management 4Q Saxo Bank A/S Saxo Bank Group

A. Introduction. (International) Central Securities Depository

(Text with EEA relevance)

3. In accordance with Article 14(5) of the Rules of procedure of the EBA, the Board of Supervisors has adopted this opinion.

COMMISSION DELEGATED REGULATION (EU) No /.. of

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

Public consultation. on a draft Addendum to the ECB Guide on options and discretions available in Union law

Information on Capital Structure, Liquidity Coverage and Leverage Ratios as per Basel-III Framework as at June 30, 2016

Regulatory Capital Disclosures

Response of the AFTI. Association Française. des Professionnels des Titres. On European Commission consultation

DRAFT JOINT STANDARD * OF 2018 FINANCIAL SECTOR REGULATION ACT NO 9 OF 2017

AMF position ETFs and other UCITS issues

Consultation Paper. Draft Guidelines EBA/CP/2018/03 17/04/2018

The Goldman Sachs Group, Inc. PILLAR 3 DISCLOSURES

Opinion of the European Supervisory Authorities

Consultation paper on CEBS s Guidelines on Liquidity Cost Benefit Allocation

Pillar 3 U.S. Liquidity Coverage Ratio (LCR) Disclosures. For the quarter ended September 30, 2017

Official Journal of the European Union. (Non-legislative acts) REGULATIONS

Client Classification Policy

Public consultation. on a draft Addendum to the ECB Guide on options and discretions available in Union law. Explanatory memorandum

Advisory Guidelines of the Financial Supervision Authority. Requirements to the internal capital adequacy assessment process

The BBA is pleased to respond to this consultation on the net stable funding ratio. Please find below are comments on the key issues in the paper.

Goldman Sachs Group UK Limited. Pillar 3 Disclosures

May Guidelines on LCR Calculation for the Interim Observation Period

a central counterparty, the registration and supervision of trade repositories and the requirements for trade repositories

SAUDI ARABIA. Annex I: Banks

BANK STRUCTURAL REFORM POSITION OF THE EUROSYSTEM ON THE COMMISSION S CONSULTATION DOCUMENT

The Goldman Sachs Group, Inc. PILLAR 3 DISCLOSURES

ICAAP Q Saxo Bank A/S Saxo Bank Group

CP ON DRAFT RTS ON ASSSESSMENT METHODOLOGY FOR IRB APPROACH EBA/CP/2014/ November Consultation Paper

The. IFRS Global Banking Newsletter. Spotlight on IFRS 9. How do you compare? Fair value disclosures

Final Report Technical advice, draft implementing technical standards and guidelines under the MMF Regulation

DFAST Public Disclosure: Texas Capital Bancshares 2015

LIQUIDITY COVERAGE REQUIREMENT UNDER THE DELEGATED REGULATION OF THE EUROPEAN COMMISSION AND BASEL III RULES 1

March 27, Japanese Bankers Association

COMMISSION DELEGATED REGULATION (EU) No /.. of

Subject: The EBA s views on the adoption of IFRS 9 Financial Instruments (IFRS 9)

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

FESE views on the Review of the Prudential Framework for Investment Firms

ESMA, EBA, EIOPA Consultation Paper on Initial and Variation Margin rules for Uncleared OTC Derivatives

Deutsche Bank welcomes the opportunity to provide comments on the above consultation.

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

ESMA Risk Assessment Work Programme 2017

5.4 Banks liquidity management regimes and interbank activity in a financial stability perspective*

Consultation response

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

NPL Regulatory Developments EBA perspective

Lombard Odier Group Pillar 3 Disclosures at 30 June 2018

Northern Trust Corporation Liquidity Coverage Ratio Public Disclosure

Questions and Answers ESMA s guidelines on ETFs and other UCITS issues

ECB Guide on options and discretions available in Union law. Consolidated version

European Association of Co-operative Banks Groupement Européen des Banques Coopératives Europäische Vereinigung der Genossenschaftsbanken

Transcription:

ABI Response to EBA Discussion Paper On Defining Liquid Assets in the LCR under the draft CRR March 2013 POSITION PAPER

Index General considerations...3 Proposals to EBA... 3 Arguments in favor of proposal 1)... 3 Additional considerations for possible objections regarding proposal 1)... 5 Position Paper Pagina 2 di 5

General considerations Proposals to EBA 1) ABI acknowledges the importance and the difficulty of the EBA exercise. ABI has analysed the detailed suggestions of the proposed methodology, and has noted that the methodology for combining different liquidity metrics together and return a relative ranking is not disclosed in the document and has come to the following considered proposal: EBA and the national supervisory authorities could substantially benefit from using what is already in place and well tested in terms of the liquidity categories for marketable assets for the Eurosystem credit operations. In the following paragraphs we will better detail the reasons behind our proposal number 1. 2) Furthermore ABI proposes to adopt a twofold approach with the ECB methodology being the standardised approach and the possibility allowed to more sophisticated banks to use their own analysis subject to local regulatory approval. This approach could overcome some methodological weakness embedded in a standardized approach. Just to give an example at page 16 of the Discussion Paper the Credit Rating is considered the only general explanatory characteristics specific to an asset that takes into account credit risk. Credit ratings are an acceptable solution but they are not the best driver that can be used to explain the link credit-liquidity because of the cliff effects generated by down/up ratings procedures and transaction inspired by regulatory arbitrage. An alternative solution within an internal model could be the use of credit spreads that can be considered an objective an uninterrupted market assessment of the credit-liquidity relationship. Arguments in favor of proposal 1) In order to promote a smooth financial market functioning, under normal and stressed conditions, it is important to reduce as much as possible the uncertainty about the EBA work definition of buffer for liquidity, both in terms of its length and of the final outcome. We would like to draw the attention on the benefits granted by the simple and pragmatic approach proposed by ABI. Following the Guideline of the European Central Bank on monetary policy instruments and procedures of the Eurosystem leads to: - minimize any unintended negative consequence on the smooth market functioning, since any EBA unjustified divergence from ECB is going to have a remarkable impact inter alia on: the repo market, and in particular the asset categories eligible for certain baskets and the related haircuts; any collateral management, margined business and central counterparties (CCP) activities, both in terms of eligibility criteria and risk control framework; the trading activity for any financial instruments included in the (Liquidity Coverage Ratio (LCR) definition, especially in terms of trading limits by risk management offices. Pagina 3 di 5

- efficiently and effectively leverage on the several years of experience and testing by the Eurosystem, and especially the ECB risk management. As proven by the EBA consultation paper, the liquidity measurement is a sensitive and difficult subject, which in our view should neither be subject to banking supervisory discretion nor diversified by location, at least in the EU. The EBA approach risks going in this direction. - leverage on the competence accumulated over years on an issue where securities supervisors and central banks may have an important experience to share. Central banks are knowledgeable mainly because of the expertise gathered in the implementation of monetary policy (collateral management, risk management), which requires, to be effective, a smooth market functioning, financial integration and financial stability. - further promote cooperation between the EBA and the ECB in view of the forthcoming supervisory responsibilities for the ECB. - cope with the criticisms that the approach presented in the discussion paper will certainly create. Its major flaws in or view are: Regime shift: statistical evidence based on 2008-2012 period would not bring meaningful results for predicting future behavior of potentially liquid assets since there will be a major regime change with the introduction in the EU of the Financial Transactions Tax (FTT) that will cause a serious distortion in the functioning of private financial markets. Moreover the new Basel 3 regulation itself will create a drastic change, since any asset that will be classified by Regulators as highly liquid will benefit of increased liquidity and any asset not eligible will experience a less liquid market place Data availability: transactional data may only be available for a limited set of asset classes and financial instruments (e.g. not for repo transaction, not for many assets that are liquid but not actively traded since they are priced in relative value terms, ). Especially from a liquidity perspective quantitative repo data is necessary for a correct assessment of the underlying liquidity characteristics Qualitative or quantitative analysis? Many of the explanatory characteristics (e.g. large number of market makers, traded via additional platforms and markets, wide range of potential buyers) cannot be handled in quantitative terms, since they are more qualitative (e.g. five not very active market makers could be much less effective in providing liquidity than two big ones; number of buyers is largely depending on pricing and risk taking capacity in a specific moment) 1. (see also question 4 of the discussion paper) Biased and not replicable results: the proposed approach might bring to biased results since it is not taking into account that many assets are priced and traded in relative value terms: even if the actual volumes traded are low, certain assets could be very liquid because highly correlated with other liquid assets. It is also to be mentioned that the proposed approach could never be replicated or back-tested by the banks (because of data availability and resources) so the institutions would not be in the position to challenge it or improve it 2. 1 See also question 4 of the discussion paper 2 See also question 5 of the discussion paper Pagina 4 di 5

Additional considerations for possible objections regarding proposal 1) On the scope: One may argue that the scope of the Eurosystem list of eligible assets is not consistent with the EBA exercise. In contrast, the list of ECB eligible assets which does not include gold, equities and commodities - is sufficiently broad in terms of issuer location (EEA plus G10), issuer type (all), asset type (all relevant), currency denomination (most relevant currencies) and creditworthiness. This implies that the Eurosystem scope is compatible with the EBA scope since there should be sufficient information for EBA to make use of the Eurosystem classification for most of the relevant assets to be included in the LCR. EBA could focus its efforts on those asset categories not included in the broad list of ECB eligible assets or on minor countries and less relevant currencies or major not EU currencies. ABI will be glad to collaborate to this. On the objective: it could be argued that the objective, and more specifically the time horizon, of the ECB risk management differs from those of the banking supervisory authorities. In the event this applies, this should not be leading to a different methodology to assess the market liquidity of asset categories rather to different inputs for parameters, such as the time horizon, which the ECB uses when computing the haircuts for the different liquidity categories. In order to be market-neutral, the methodology applied by EBA should be dependent on the types of instruments and their markets, not on the banking supervisors objectives. It would have unforeseen market consequences to be assessed, if EBA methodology was diverging from the Eurosystem methodology, without justification. On the data: one may argue that the ECB is not in the same position than European supervisors in particular ESMA, in terms of data availability for the executed transactions. This seems a valid counterargument. It is positive that EBA is willing to use, as primary source of data for debt securities, the transaction reporting databases held by national authorities, which were created due to mandatory reporting requirements under the Markets in Financial Instruments Directive (MiFID). It would be even better if a single centralised database was set-up and used by ESMA and EBA. As preferred option, ABI would encourage a fruitful cooperation between the European supervisory authorities and the ECB in terms of data exchange, also for the purpose of defining liquidity measurement methodologies. On CRR categories (Level 1 and Level 2): these could be easily derived considering Table 6. For example Level 1 asset are those belonging to the first second and third ECB liquidity categories while for the remaining asset (Level 2). Pagina 5 di 5