Covid 19 WSBI Statement

United efforts indispensable to overcome crisis

We welcome both the decision to update the Supervisory Review and Evaluation Process (SREP) Guidelines and the overarching objectives to increase convergence of practices across the EU and to align with other relevant EBA Guidelines.

The financial industry faces an unprecedented challenge that may last for quite some time due to the coronavirus pandemic, states a letter for policymakers worldwide from savings and retail banking association WSBI. Signed by its President Isidro Fainé and Managing Director Chris De Noose, the letter says focus starts with saving as many lives as possible, eradicating the coronavirus pandemic and ensuring that the so-called “real economy” suffers as little as possible from vast Covid-19-caused economic damage.

Support measures done so far by governments can help SMEs, WSBI writes, expecially the the self-employed and individuals, as well as larger, heavily affected industries such as the services sector at large, in particular manufacturing, transport and tourism.

“Economic, financial, fiscal and social measures need to be designed and implemented straightaway, the letter states, adding “international cooperation is of utmost importance. The world needs to face the coronavirus crisis with decisive actions in a united and well-coordinated manner.”

Committed to people, communities, SMEs and beyond

Savings and retail banks fully commit to supporting their customers, the letter states, be it individual people, families, SMEs, institutions, young people, the elderly and society in general who live in urban as well as in rural areas. “We aim to figure out the best, sustainable solutions. Locally rooted savings and retail banks have a crucial stabilising function in times of crisis with their infrastructure, closer relationship with customers and continuous lending.” WSBI member banks help SMEs and other companies overcome liquidity bottlenecks and provide stability. “For this to succeed,” WSBI added, “everything possible should be done in regulatory and macroprudential terms to maintain the liquidity and credit supply.”

On firmer footing since crisis

Playing an essential part of the solution, savings and retail banks see major financial reforms during the past decade have made their banks safer, more stable and more resilient in the face of shocks. Facing the coronavirus on stronger footing, their inclusive and socially committed approach to banking remains vital and steadfast during challenging times like these, they note.

WSBI added: “Clients of savings and retail banks can continue to rely on their banks as partners that do their utmost to mitigate the effects of this critical situation. Now, more than ever, we will stand strong to provide confidence, comfort and trust when customers and communities need it most.”

Policy ideas to give banks enough flexibility

WSBI members welcome the measures already taken by authorities, and proposes ideas to give banks “enough flexibility to continue supporting their customers. Some steps already taken need additional guidance and extended scope to achieve their objectives.” They include:

  • temporarily relax the rules when it comes to capital and liquidity buffers
  • increase monitoring, develop contingency plans and provide additional support for the most hard-hit sectors – tourism, transportation and the hospitality industry – by easing the tax burden for certain much-affected firms in vulnerable regions.
  • a plan to recover economic activity and production of goods and services and to stimulate consumption to prevent the economy from recession.
  • public authorities should free up additional capital and provide loan guarantees
  • flexibility on the asset quality assessment of loans by supervisors when public moratoria on payments have been implemented. This would also strengthen banks in temporarily supporting solvent clients facing liquidity difficulties.

IFRS 9 accounting standard implementation for the recognition of loan loss provisions should take into account the disruptive Covid-19 crisis. It is crucial that banks are granted enough manoeuvring room to modify the payment schedule of the affected borrowers without affecting their accounting provisions nor their solvency; that is, avoiding the increase in non-performing assets that would derive from the current regulations.

​Global coordination, relief measures much needed

At national and regional level, much can be done through coordination among policymakers, keeping neighbors in mind. At a global level, need exists for G20 to prioritise global financial stability, a sustainable and swift recovery and a balanced development as common goals. The recent G7 leaders’ commitment to do ‘whatever is necessary’ to support the global economy, a very well received first step, but future decisions regarding interpretation, adjustments, and tailoring of regulations must be properly coordinated at global level via the Financial Stability Board, the Basel Committee, the International Organization of Securities Commissions and the International Association of Insurance Supervisors. The IMF has also underlined the need for global coordination in its recent paper on policy.

What happens next

WSBI suggests in its statement that regulatory authorities ask themselves if new regulatory requirements that are planned to be implemented in 2020-2022 are critical, or, if there is a possibility, that they can be delayed by 1-2 years, depending on how the crisis further develops. Even if only a part of the upcoming regulation could be delayed this would certainly help banks, and other players, to focus their resources on critical immediate action.

Once the emergency has been overcome and the situation is stable, it may be useful to carry out an impact assessment in order to see what measures should be taken to ensure that the global economy is still growing.

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WSBI statement on Covid-19: united efforts to overcome the crisis are indispensable

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On the EBA guidelines for Anti-Money Laundering Compliance Officers

We welcome both the decision to update the Supervisory Review and Evaluation Process (SREP) Guidelines and the overarching objectives to increase convergence of practices across the EU and to align with other relevant EBA Guidelines.

ESBG calls for several clarifications and amendments.

Particularly, in light of the different transposition of the AML Directive, it is of utmost importance that, where a conflict is unavoidable, national specificities prevail guideline provisions.

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On the EU Commission evaluation of the Mortgage Credit Directive

After the ESBG meeting with the European Commission on 30 September, we have recently shared some documents as a follow-up.

ESBG members finalised a position paper on the MCD review, and shared two briefing documents on the topics of reverse mortgages and green/energy efficient mortgages. These are topics on which the Commission is keen to receive more information from the national level to consider possible actions at the EU level.

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ESBG welcomes EBA's greater emphasis on proportionality

ESBG welcomes that the EBA is placing greater emphasis on proportionality in regulation, and hopes that this will pave the way for more proportionality in future regulations. However, more can be done to improve the proposed classifications, increasing granularity and have a paper which better explains how the ideas could be implemented.

We welcome the EBA’s commitment to using, primarily and as far as possible, already existing data from its database of supervisory reporting. However, if more data is required from financial institutions, we urge the EBA to deliver on the promise that these collections are proportionate to the complexity of the underlying requirements itself and to the burden of institutions and supervisors to deliver such data.

We consider the step-by-step approach to be suitable in principle. However, the procedure in step 2 is not clear. In our view, the proposals for the metrics are not yet fully developed. It is not sufficiently clear how on this basis – without concrete benchmarks – the decisions of a political expert can be better supported.

ESBG very much appreciates the inclusion of a classification for co-operative and savings banks. These banks are by nature local, rather small banks with a low-risk profile and a focus on core banking business. We urge the EBA should ensure that the proportionality considerations are also applied to small and non-complex institutions that are part of a consolidated group, particularly credit institutions that are only locally/regionally active and therefore do not have a systemic impact.

We would like to point out that Classification III has clear disadvantages compared to Classifications I and II. Institutions that are to be subject to the strictest regulation are to be delimited by means of a size criterion (€ 30 billion balance sheet total; point 31 lit. d of the EBA discussion paper). A delimitation on the basis of the balance sheet total would contradict the basic idea of a sufficiently differentiated regulation on the basis of the pro-portionality principle.

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ECB announces members of Digital Euro Market Advisory Group

ECB appoints 30 senior business professionals with proven experience. Members to advise Eurosystem on design and distribution of potential digital euro. Meetings of group to be held at least quarterly, starting in November 2021.

25 October 2021 – The European Central Bank (ECB) has today announced the members of the Market Advisory Group for the digital euro project.

The Eurosystem’s High-Level Task Force on Central Bank Digital Currency called for expressions of interest on 14 July, following the Governing Council’s approval of the digital euro project investigation phase. After assessing applications, the selection committee appointed 30 senior business professionals with proven experience and a broad understanding of the euro area retail payments market.

“I am pleased that many high-quality experts from the private sector are willing to contribute to the digital euro project”, says ECB Board Member Fabio Panetta, Chair of the High-Level Task Force.

“Their expertise will facilitate the integration of prospective users’ and distributors’ views on a digital euro during the investigation phase.”

Members of the Market Advisory Group will act in a personal capacity, advising the Eurosystem on the design and distribution of a potential digital euro from an industry perspective, and on how a digital euro could add value for all players in the euro area’s diverse payments ecosystem. A representative from the European Commission and representatives from Eurosystem national central banks will also participate in the group.

Meetings are to be held at least quarterly, starting in November 2021, and written consultations will be organised between meetings. The issues identified will also be considered in the Eurosystem’s established forum for institutional dialogue on retail payments, the Euro Retail Payments Board (ERPB). The ERPB consists of high-level representatives of industry associations and represents a wide range of stakeholders. In addition, the Eurosystem will engage with the public and merchants through dedicated surveys (e.g. of focus groups) and will continue to hold technical workshops with the industry.

Members of the Digital Euro Market Advisory Group:

Aleksander Kurtevski, Managing Director, Bankart
Alessandro De Cristofaro, Director Digital Innovation Strategy, CRIF
Antonio Macías Vecino, Head of Payments Discipline, BBVA
Axel Schaefer, Payment Regulation and Innovation Specialist, Ingka Group (IKEA)
Cristian Cengher, Product Owner Cross Border Payments, Erste Group Bank AG
Cyril Vignet, Project Manager Innovation, Banque Populaire Caisse d’Epargne
Diederik Bruggink, Head of Payments and Innovation, European Savings and Retail Banking Group
Etienne Goosse, Director General, European Payments Council
Fanny Solano, Director Digital and Retail Regulation, Transparency and Implementation, CaixaBank
Fernando Rodríguez Ferrer, Head of Business Development, Bizum
Gerard Hartsink, Chairman, ICC DSI Industry Advisory Board
Inga Mullins, CEO, Fluency
Jens Holeczek, Head of Digital Payment Unit, National Association of German Cooperative Banks
Jochen Siegert, Managing Director, Global Head of Asset Platforms, Deutsche Bank AG
Nicolas Kozakiewicz, Chief Innovation Officer, Worldline
Nilixa Devlukia, CEO, Payments Solved
Nils Beier, Managing Director, Accenture Strategy & Consulting
Paul Le Manh, Advisor to CEO, EPI Interim Company
Piet Mallekoote, Former CEO, Dutch Payments Association
Régis Folbaum, Head of Payments, La Banque Postale
Roberto Catanzaro, Chief Strategy and Transformation Officer, Nexi Group
Ruth McCarthy, Managing Director, FEXCO Corporate Payments
Sean Mullaney, Head of Payment Engineering, EMEA Payments, Stripe
Silvia Attanasio, Head of Innovation, Associazione Bancaria Italiana
Sofia Lindh Possne, Senior Advisor, Group Regulatory Affairs, Swedbank
Stefano Favale, Head of Global Transaction Banking, Intesa Sanpaolo
Teresa Mesquita, Chief Marketing and Product Officer, SIBS Forward Payment Solutions
Valdis Bergs, Chairman of the Board, Mobilly sia
Ville Sointu, Head of Emerging Technologies, Nordea
Yves Blavet, Open Banking Director, Société Générale

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The EU Commission’s proposed ‘single-stack’ approach for Basel III finalisation would harm European banks

ESBG also calls for a proportionate implementation of the Basel III framework in the EU banking system to ensure that Europe’s diversified banking sector continues to foster economic growth.

BRUSSELS, 27 October 2021 – The European Savings and Retail Banking Group (ESBG) calls on the European Parliament and the Council of the EU to reconsider the output floor implementation on a ‘single-stack’ approach included in the European Commission’s proposal for the finalisation of the Basel III standards in the EU, announced today.

The ‘single-stack’ approach would mean applying the output floor to EU-specific capital requirements, on top of internationally agreed ones. ESBG calls for the use of the ‘backstop approach’, meaning applying the floor only to internationally agreed capital requirements. The ‘backstop approach’ would help preserve and strengthen the EU’s diverse banking system. Otherwise, the ability of Europe’s diversified banking sector to provide finance to the real economy and foster economic growth could be hampered.

“ESBG and its members believe that the Co-legislators should implement the Basel III framework adapting it to the specificities of the European banking market, where needed. This includes an application of the output floor that does not exceed what is explicitly laid down in the agreement on the finalisation of Basel III”, said Johanna Orth, Chair of ESBG’s Task Force on Basel.

The package of reforms to finalise the Basel III framework is designed for internationally active banks. Therefore, when implemented within the EU regulatory framework the EU special features should be considered, including those which are already enshrined in the banking regulation. In particular, the so-called SME supporting factor should be retained, as it provides the right incentive to stimulate real economic growth.

“The implementation of the Basel standards within the EU regulatory framework should reflect the proportionality principle, taking into consideration the risk nature, scale and complexity of the activities of European credit institutions”, said ESBG Managing Director, Peter Simon.

This would allow financial institutions to carry out their activities under a non-detrimental regulatory framework which strengthens the European banking sector – the backbone of the EU’s ‘real economy’. A disproportionate regulatory weight also would negatively impact banks, which would be overburdened with regulatory requirements that could even push resources away from customer service.

The EU banking sector’s diversity ensures that a full range of services is offered to customers at competitive prices, in particular by banks that focus on SMEs, households and local communities.

In this context, ESBG is looking forward to bringing the voice of its members to the upcoming legislative process. We believe that close cooperation among all stakeholders will be indispensable for the successful implementation of the finalised Basel III standards. We encourage the EU decision-makers to make full use of the discretions envisaged in the Basel III text, including those on operational risk, which will be crucial for continuous and solid credit provisions to the real economy after the implementation phase.

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Bank financing for SMEs must be protected in Basel III finalization

The European Parliament (EP) should revise the measures that would eventually limit bank financing for ’unrated companies in the European Commission (EC)’s proposal for the finalisation of Basel III standards, said yesterday MEP Markus Ferber, Coordinator for the EPP Group at the EP’s Committee for Economic and Monetary Affairs (ECON).

At a panel discussion organised by the European Savings and Retail Banking Group (ESBG), the parliamentarian said that most SMEs are likely to be ‘unrated companies’ and do not have the resources to get external rating, in contrast to large companies.

“I really want to safeguard that SMEs have access to financing and I’m not very convinced that Commission’s proposal on the unrated corporates is the solution”, he said to the agreement of most of his fellow speakers at the panel discussion ‘The impact of Basel III implementation on the EU economy’.

“We hear the concern about all those corporate clients of the banks who don’t have an external rating” said Johanna Orth, Head of Group Regulatory Affairs at Swedbank and Chair of the ESBG Task Force on Basel IV, who moderated the discussion. The Commission’s solution of a preferential risk weight for unrated companies during a transitional period ending in 2032 is “highly appreciated but still has an end date”, she stressed.

ESBG’s over 800 members are savings and retail banks who have SMEs as some of their main clients and have an important role as a motor of the EU’s real economy.

The EC’s DG FISMA Head of Banking Regulation and Supervision, Almoro Rubin de Cervin, had kindly given a brief presentation of the EC’s proposal announced at the end of October.

One of the key issues for the EU’s financial sector moving forward will be “to advance with the banking union”, said MEP Jonas Fernandez, EP’s ECON Coordinator for the S&D Group.

CaixaBank’s Head of Public Affairs, Christian Eduardo Castro, considered the EC’s Basel finalisation proposal “well-balanced and realistic” but called for some revisions, including on equity investments and disclosure requirements regarding operational risk.

ESBG Managing Director, Peter Simon, closed the event, the first one organised in ‘hybrid’ mode. “This type of dialogue is important to enhance the cooperation between all stakeholders to ensure proper and well-balanced implementation of the final Basel III standards”, he said.


Review of the EBA SREP Guidelines

We welcome both the decision to update the Supervisory Review and Evaluation Process (SREP) Guidelines and the overarching objectives to increase convergence of practices across the EU and to align with other relevant EBA Guidelines. Nevertheless, the draft version of the Guidelines contains specific provisions that go further than the EU Directive (CRD). In addition, the fact that the scope of provisions set out in the Guidelines has been expanded yet again gives rise to fears that proportionality aspects under Pillar 2 will be pushed further into the background.

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Proposal for a Regulation on European green bonds

Proposal for a Regulation on European green bonds

Establishing a European green bond standard (‘EUGBS’) was an action in the Commission’s 2018 action plan on financing sustainable growth and is part of the European Green Deal.

The European Commission adopted its proposal for a EUGBS in July 2021 and later launched a public consultation. In this context, ESBG has recently finalised a position paper that indicated some of the main concerns with the adopted proposal.

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BRAC Uganda working in Covid times

Maintaining customer and investor confidence during Covid

Improved liquidity position allows financial service providers to focus on pandemic recovery

The Covid-19 pandemic is the latest crisis that is putting pressure on financial service providers (FSPs) globally. Lockdowns and regulatory moratoriums on loan repayments, together with a lower business activity are putting serious constraints on FSP’s liquidity positions. Early in the Covid pandemic, there was widespread concern that liquidity constraints could wipe out many of the financial institutions that serve low-income customers and small- and medium sized enterprises.

Two recent reports issued by CFI/e-MFP and CGAP point to the vital importance of managing liquidity in the midst of a crisis. After all, the quickest path to failure of an FSP is running out of cash. Available liquidity should be used to retain the confidence and trust of both customers and creditors while continuing to operate and paying staff.  Once stability is achieved, an FSP can start its recovery, but this cannot be achieved without retaining the confidence of customers, investors, staff, and the regulator.

Evidence of successful crisis response

Scale2Save is a partnership between WSBI and the Mastercard Foundation to establish the viability of small-scale savings in six African countries. To analyse the impact of the Covid crisis on the liquidity profile of our partner FSPs, we compared the pre-crisis liquidity position at end of year 2019 with that at end of 2020 when a cautious and gradual recovery of the Covid pandemic had set in. Across our programme partners, we collected liquidity gap reports from four banks and three deposit taking microfinance institutions in four countries: Ivory Coast, Nigeria, Morocco, and Uganda.

Liquidity risk arises from both the difference between the size of positions of assets and liabilities and the mismatch in their maturities. When the maturity of assets and liabilities differ, an FSP might experience a shortage of cash and therefore a liquidity gap. A liquidity gap report profiles assets and liabilities into relevant maturity groupings based on contractual maturity dates and is an important tool in monitoring overall liquidity risk exposure. A liquidity gap report is a standard disclosure included in audited financial statements of our project partner institutions.

Increased customer deposit balances

All partner financial institutions increased their customer deposit volume at the end of 2020 compared to pre-Covid crisis level. Perhaps more importantly, they also mostly managed to increase the proportion of customer deposit funding as part of total liabilities, as seen in the graph below.

The partner banks seem to have been more successful in increasing deposit volume compared to microfinance institutions. However, caution needs to be taken in generalising this conclusion as country and institution specific factors are also at play.

Lower dependency on borrowed funds

International creditors have been very supportive to banks and microfinance institutions during the Covid crisis, granting waivers for breaches of loan covenants, providing for temporary suspensions of interest and loan repayments, restructuring of loan terms and new financing. However, given the ample liquidity available from customer funding and the higher cost associated with international borrowings and debt issuance, most partner institutions chose to run-off these borrowings during 2020 lowering the proportion of borrowings in the funding mix. The average maturity of outstanding debt dropped as a result, as the following graph reveals.

Improved liquidity profile

The maturity of customer loans and advances increased during the crisis due to loan moratoriums and the related rescheduling and restructuring. The loan maturity loan terms of all partner FSPs extended, with one example of a 216% increase, seen below, in the case of an institution which generally has extremely short loan maturities.

On the liability side, contractual maturities of funding decreased for all partner FSPs, except one.  This was mainly the result of international borrowings that expired or that were not rolled over.

When considered from the perspective of contractual maturities, the combination of lengthening loan terms and shorter funding maturities would suggest a worsening of the structural liquidity position of an FSP. However, the anticipated maturity of retail customer current accounts, security and savings deposits is often much longer than their contractual maturity, when taking into account the behavioural characteristics of a large and diversified pool of individual accounts that exhibit “stickiness”. Only a proportion of these retail customer balances will be drawn down on contractual maturity date and the entire pool provides a more stable, long-term source of funding.

This point can be illustrated with reference to the international liquidity standards issued by the Basel Committee on Banking Supervision for the calculation of expected cash outflows for two key liquidity risk indicators, the liquidity coverage ratio (LCR) and the net stable funding ratio (NSFR). The Basel standards assume that between 3% and 10% of retail deposits[1] would actually run-off over the next 30 days under an adverse liquidity scenario. The corollary of this is that 90-97% of retail deposit funding can be considered to be stable in nature and of longer duration. As short-term customer account funding (<30days) of our partner institutions make up a significant proportion of the total customer funding (between 30% and 90%), a large part of these funds can therefore be considered as “core” and provide a stable funding base to compensate for the extended loan maturities from Covid impacted loan rescheduling.

The Basel global liquidity standards are meant as guidance and FSPs operating in less developed markets and more volatile environments may experience higher deposit run-off rates in case of liquidity stress.  Nevertheless, a significant proportion of our partners’ customer account and savings balances can be considered as stable.

Institutional resilience in face of the Covid crisis

At the outset of the Covid crisis, our partner institutions invoked their pandemic crisis management plan and took protective measures for customers and staff to prevent infection and transmission.  Partner institutions granted credit relief to borrowers in the form of loan moratoriums in line with regulatory forbearance measures.  Digital access to customer accounts was stepped up, so customers could meet household consumption expenditure during the lockdown.

Our partners have withstood the liquidity stress induced by the Covid crisis and successfully retained the confidence of customers and investors.  With a cautious and gradual recovery from the Covid pandemic underway, FSPs can now focus on recovery steps higher up the hierarchy of financial institutions crisis management needs.  These needs were described in the CFI/e-MFP report in the following order of priority: liquidity, confidence, portfolio and capital.

With stability restored, FSPs can now shift their recovery efforts to managing the loan portfolio by balancing collections of overdue loans with the need to continue lending to reliable low-income customers and small- and medium-sized enterprises and maintaining capital adequacy levels when Covid-related regulatory forbearance measures will expire.

Through surveys and case studies the Scale2Save programme continues to investigate the driving factors that influence the different outcomes of Covid crisis management.

A blog published on the European Microfinance Platform (e-MFP). To read the original version (including graphs) visit this page.

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