ESBG’s letter to the Commission on the EBA RTS and GL on interest rate risk in the banking book
On 20 December 2022, ESBG sent a letter to the European Commission about the draft EBA Regulatory Technical Standards (RTS) on interest rate risks for banking book (IRRBB) supervisory outlier tests (SOT) and EBA Guidelines on IRRBB and credit spread risk in the banking book (CSRBB).
Whilst we support a revision of the framework capturing interest rate risks for banking book positions, we also believe that the 2,5% SOT threshold for the definition of “large decline” in net interest income (NII) suggested by the EBA is not appropriate as it was calibrated in a low interest rate environment. We therefore suggested that the EBA continues monitoring the normalisation of the monetary policy and only re-calibrates the threshold at a later stage more in line with current market conditions. Furthermore, we pointed out that the relative quantitative impact study was performed at consolidated level and only with a small number of large banks, which makes the calibration of the threshold even less appropriate.
Furthermore, in order to avoid different interpretations and ensure a level playing field, we stressed in relation to the EBA GL on IRRBB and CSRBB that non-marketable instruments, e. g. loans to customers, should be generally exempted from the scope of the CRSBB framework. The value of these instrument is not exposed to market fluctuations, moreover they are already covered through banks’ credit risk management processes.
The European Commission is currently reviewing the EBA RTS on IRRB SOT and is allowed to propose amendments to the text, which would eventually need to be assessed by the EBA. The Commission aims to publish the final RTS around mid-2023. For what concerns the EBA GL on IRRBB & CSRBB, the Commission cannot propose amendments but may suggest a revision to the EBA.
Looking ahead, ESBG will continue to remain engaged with the Commission during the review process.
Read the Full Letter
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ESBG responds to the ESAs call for evidence on greenwashing
The European Supervisory Authorities (ESMA, EBA, EIOPA) received a request for input from the Commission relating to greenwashing risks and supervision of sustainable finance policies. Therefore, they asked for input on potential greenwashing practices in the EU financial sector. On 10 January 2023, ESBG provided the ESAs with its contribution.
ESBG welcomes this call for evidence since greenwashing is an issue which must be tackled at the EU-level and would like to recall that banks and savings banks are intensively dedicated to the traceability, transparency and credibility of the sustainability features they have to consider in investment advice and financial portfolio management. The EU Taxonomy, the Sustainable Finance Disclosure Regulation (SFDR) and the Markets in Financial Instruments Directive (MiFID II) already aims at tackling greenwashing. Nonetheless, ESBG regrets that these different regulations are currently based on a different understanding of greenwashing. The existence of a large amount of complex ESG information and data that needs to be provided to investors and clients can also create a perverse effect through an information overload which can facilitate greenwashing.
Therefore, in the interest of customers, banks, saving banks and issuers of financial products, ESBG assesses that there is an urgent need for a harmonization of the understanding of greenwashing within the framework of European legislations and supervisory practices. ESBG believes that it could be achieved through the following steps:
- First, there is a need to strengthen transparency through a consistent enforcement of existing EU regulations’ requirements.
- Then, a clear and scientifically comprehensible, as well as uniform legal definitions of both sustainability and greenwashing for financial instruments must be implemented, keeping in mind the need for practicality and feasibility for banks and saving banks when implementing these requirements.
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ESBG provides input on technical negotiations of the Artificial Intelligence Act
In Q4 of 2022, ESBG staff was invited to three stakeholder info sessions on the technical negotiations on the Artificial Intelligence Act, organized by the offices of MEP Voss (EPP, LIBE Shadow/JURI Opinion), MEP Clune (EPP, LIBE Shadow), and MEP Maydell (EPP, ITRE Opinion). During these info sessions, stakeholders were updated about the articles discussed during the technical meetings that took place in the Parliament and invited to provide concrete input on concrete issues.
The definition of AI remains a highly debated issue. According to ESBG members, the proposed definition is currently too broad. ESBG members argued for a narrow scope, since a scope that is too broad could potentially include more traditional software systems that should not fall under the scope of the proposal The definition of AI needs to take into account the different levels of autonomy and explainability of the system, as well as the level of control and human participation. Furthermore, it must contain the ability to learn and reason as central element.
Stakeholders were also asked for concrete examples of overlap with other pieces of legislation, also of sector-specific legislation. ESBG pointed out a number of articles where overlap with other legislation, notably the GDPR exists. There has also been discussion on the high-risk classification, extraterritorial applications, cooperation mechanisms, and access to data. Therefore, ESBG provided input on those matters as well.
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Crypto-asset Activities: WSBI-ESBG calls for a more consistent regulatory approach
The Financial Stability Board (FSB) which is an international body that monitors and makes recommendations about the global financial system published a proposed framework for International Regulation of Crypto-asset Activities on 11 October 2022. The said framework sets out a) the key issues and challenges in developing a comprehensive and consistent regulatory approach that captures all types of crypto-asset activities that could rise to financial stability risks; b) policy initiatives at the jurisdictional and international levels; c) the FSB’s proposed approach for establishing a comprehensive framework.
The FSB reports that crypto-assets and markets must be subject to effective regulation and oversight commensurate with the risks they pose. Crypto-asset markets are fast evolving and could reach a point where they represent a threat to global financial stability due to their scale, structural vulnerabilities and increasing interconnectedness with the traditional financial system.
WSBI-ESBG, for its part, welcomed the initiative of addressing the above-mentioned crucial issues and replied to the call for feedback on this consultative document on a proposed framework for International Regulation of Crypto-asset Activities, in particular calling for a more measured regulatory approach between the several players (i.e.; financial institutions, issuers, and providers of crypto assets) and for consistency between regulations and requirements applicable to traditional finance and crypto-based finance.
Finally, members underlined the importance of having a clear and dynamic regulatory approach to avoid confusion on the categorization of crypto-assets (i.e.; stablecoins, global stablecoins, digital assets), and the need for a higher consistency between local and international regulations.
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WSBI-ESGB members call for aligned approach between regulatory bodies on Cyber incident reporting
On 17 October 2022, the Financial Stability Board (FSB) published a consultative document on Achieving Greater Convergence in Cyber Incident Reporting (CIR). In parallel, the FSB invited feedback on this document. Back in 2021, the FSB already published a report on CIR. The report set out three ways the FSB would take work forward to achieve greater convergence in cyber incident reporting: developing best practices, creating common terminologies for CIR, and identifying common types of information to be shared across jurisdictions and sectors.
To inform on its work, the FSB conducted a survey amongst FSB members to identify the most common reporting objectives and types of reporting performed; understanding the practical issues financial authorities and financial institutions have in collecting or using incident information; identifying the information items authorities collect to meet the common reporting objectives, including a review of existing incident reporting templates; and exploring the mechanisms for financial authorities to share incident information across borders and sectors.
Drawing on the survey findings, the FSB has set out recommendations to address impediments to achieving greater convergence in CIR with a view to promote better practices. This work also helped to inform refinements to the Cyber Lexicon, which resulted in the addition of four terms and revision of three definitions. The FSB also reviewed financial authorities’ incident reporting templates and identified commonalities in the information collected. Leveraging on this work, the FSB presented a concept for a format for incident reporting exchange (FIRE) to promote convergence, address operational challenges arising from reporting to multiple authorities and foster better communication.
In the face of the above mentioned initiative, WSBI-ESBG replied to the call for feedback on this consultative document on cyber incident reporting, in particular calling for a harmonised reporting approach between different regulatory bodies, processes, and data requests. In terms of promoting greater convergence in CIR, financial authorities could offer tools and platforms that minimize operational issues for reporting of incidents.
Finally, members underlined the importance of having clear definitions to avoid confusion and to differentiate between the terms ‘cyber incident’ and the subcategory thereof of ‘cybersecurity incident’.
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WSBI and BTN Collaboration Encourages Global Financial Digitalization and Inclusion
Brussels, 16 December 2022 - World Saving and Retail Banking Institute (WSBI), incollaboration with PT Bank Tabungan Negara (Persero) Tbk (BTN), held the 28th meeting of the WSBI Asia Pacific Regional Meeting. The meeting was held under the theme "Sustainable and Resilient - Savings and Retail Banks in the Post-Pandemic Era". The event was a follow-up to the results of the G20 summit in Denpasar, Bali.
WSBI Managing Director Peter Simon delivered the Paris Declaration to representatives of the Indonesian G20 Presidency. In his speech, Mr Simon insisted on the need for shared solutions to common problems that go beyond geopolitical division. To this end, he reiterated the main points of the Paris Declaration, which calls for harmonizing green taxonomies among jurisdictions following science-based, pragmatic principles. In line with the theme, there were a number of discussion topics at the Regional Meeting, which was held on December 15-16, 2022, in Bali, Indonesia. Among them are digitalization and financial inclusion, sustainability, green finance, innovation, fintech, and payments. These topics were elaborated from different perspectives: business side and regulatory.
WSBI delegation was led by WSBI – ESBG Managing Director, Peter Simon and the meeting saw the participation of many members such as the President Director of
Bank BTN, Haru Koesmahargyo, Shantan Yoosiri Senior Executive Vice President of Government Saving Bank Thailand, and a number of delegates from various countries and banks such as Imagin, CaixaBank, the Sparkassestiftung for International Cooperation, Germany, the Saving Bank of Thailand, Cambodian Bank, Xalk Bank Uzbekistan, Bostwana Savings Bank, Bostwana, the European Union Delegation to ASEAN, the European Investment Bank, European Union. This very intense three-day event was a great chance to concretely discuss best practices and share strategies both from the perspective of regulators and the banking industry. Participants learnt and discussed practical solutions to improve the reliability of green finance product data. Tools and strategies were presented for very advanced banks as well as for institutions catering for the less well-off. The European Investment Bank and the Indonesian Ministry for Housing and Public Works gave a bunch of concrete projects that are being launched in the region where socially responsible banks can play a crucial role while developing their green finance portfolio.
Media coverage in other languages
Article from : Liputan 6 (The 6 Report), Indonesian flagship television news program broadcasts on SCTV
Article from: Suara.com, a Indonesian news portal that presents informations from political, business, legal.
Article from: Media Indonesia is a national newspaper published since January 19, 1970
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Financial News & Views: December 2022 Edition
WSBI ESBG
Audience
WHAT’S INSIDE?
• New year message from WSBI-ESBG Managing Director (Page 2)
• WSBI’s president interview with The Banker (Page 3)
• World Savings Day 2022 (Page 3)
• The internal cards market in Europe from 2002 to 2020 (Page 4)
• A Female approach to financial education (Page 5)
• The very real challenge of cybersecurity and how to face it (Page 5)
• The 28th African Regional Group Meeting in Cape Verde (Page 6)
• ESBG welcomes Deputy Governor of the National Bank of Ukraine (Page 6)
• CMDI framework review: An evolution rather than a revolution (Page 7)
• Scale2Save: What a journey it has been! (Page 8)
More publications
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Joint Industry letter on the importance of advice and preserving the commission-based model
ESBG toghether with EFAMA, EBF, Insurance Europe, EACB, EAPB and EUSIPA, issued a public letter addressed to Vice-President Dombrovskis, Commissioners McGuinness and Director-General Berrigan, remarking the importance of advice for European retail investors and the need to maintain the coexistence of fee-based and commission-based advice
Joint Industry Letter
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Value for money approach: ESBG position
In September 2022, the European Commission circulated among stakeholders a Discussion Note on a “Value for Money” (VfM) approach with the aim to solicit views on how the retail investor protection framework might be enhanced through the development of an approach aimed at ensuring that products offered to retail investors offer value for money.
ESBG welcomed the intentions of the EC and DG FISMS to assess how the retail investor protection framework may be enhanced through this specific methodology, nevertheless, we believe that it should be made clear that this approach cannot work as one-size-fits-all under the entire product governance requirements. By the same logic, we wanted to stress that existing tools already provide for a “Value for Money” approach.
Therefore, we answered to the discussion note questions and we sent our position to DG FISMA with the aim of explaining why this approach should mainly focus on products distributed under investment advice, if at all. In order to prevent a distortion of the competition between manufacturers, the concept will need to be fine-tuned, taking into account the potential regulatory increasing costs of bureaucracy, calculation and daily reporting obligations.
The new regulatory regime should also contribute to diversify the supply. As it is well known, a broad range of manufacturers and products is essential to guarantee a competitive offer. For example, when EC asked to assess that certain products that are offered to consumers do not offer Value for Money, ESBG believes that there are already current requirements under product governance to address the performance of products and their costs and charges.
These are implemented through various measures taken by the manufacturers and distributors. Moreover, at the level of the distributors, a check is already carried out during the investment advice process as to whether the distributor also offers equivalent products to the product which is intended for recommendation. About which criteria should be used for an assessment of VfM, ESBG agrees that manufacturers already carry out comprehensive inquiries of the costs of their products in order to inform investors (i.e. in the PRIIPs KIDs), so that meaningful data is available on costs and charges. However, the client may take into other considerations like the horizon of investment of a piece of its savings, the level of security etc, so it is not possible to only take into account figures. The investor is usually interested in the most attractive possible return. The future return of a product cannot be predicted when it is launched.
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