On February 22, ESBG responded to the European Commission “have your say" consultation on the Banking Package proposal, which transposes the final elements of the Basel III reforms in the EU regulatory framework and pursues other prudential and supervisory objectives.
ESBG supports the application of the output floor at the highest level of consolidation. The envisaged single-stack approach however requires that supervisory powers are more clearly framed and that the arrangements mitigating its impact are of a longer-term nature or permanent. The transitional arrangements for residential real estate, unrated corporates and derivatives should be made permanent or at least phased out based on the actual observation of structural changes in the EU banking market. Moreover, these flexibilizations should be extended also to institutions using the standardised approach to maintain a level playing field.
We recognise the proposal to disregard historical operational losses for all institutions within the calculation of capital requirements for operational risk, meaning that the internal loss multiplier (ILM) is effectively being set equal to one. This is a discretion provided in the Basel framework.
As regard to equity exposures, we support the implementation of a new category with a lower 100% risk weight (RW) for long term strategic equity investments.
Regarding specialised lending, we support the proposal to increase the risk sensitivity for unrated object finance exposures.
With respect to real estate exposures, the proposed requirements for non-income producing real estate should not go beyond the Basel standards. We then support the increased risk sensitivity for acquisition, development and construction (ADC) lending.
The threshold to use the simplified credit valuation adjustment (CVA) method should be aligned with the provision in the Basel framework.
We warn against an excessively restrictive application of the credit conversion factor (CCF) to trade finance instruments and to other exposures.
The proposed centralization of the disclosures is appreciated. Small and non-complex institutions should be exempted from reporting and disclosing requirements in the area of Environmental, Social and Governance (ESG). Further proportionality elements could then be envisaged.
Furthermore, the decision to retain important EU features such as the SME and the Infrastructure supporting factors and the CVA exemptions is appreciated.
related
February 21, 2023
ESBG responded to the ESMA consultation about the use of ESG terms in funds’ names
On 17 February, ESBG submitted its response to the ESMA consultation about the use of ESG terms in funds’ names
February 3, 2023
Advocating on the EU deforestation regulation
What lessons can be learnt from a French diplomat from the XIX century?
January 11, 2023
ESBG responds to the ESAs call for evidence on greenwashing
Therefore, in the interest of customers, banks, saving banks and issuers of financial products, ESBG
October 5, 2022
Joint letter to Commissioner McGuinness on the EFRAG consultation regarding its first set of draft ESRSs
On 27 September, the ESBG, together with the European Banking Federation (EBF), the European Association of Co-operative Banks (EACB), Insurance Europe, Accountancy Europe, Business Europe and…
September 9, 2022
ESBG response to the EFRAG consultation on its first set of draft ESRSs calls to ensure levelled global playing field
In its response to the European Financial Reporting Advisory Group (EFRAG) public consultation on the first set of Draft EU Sustainability Reporting Standards (ESRSs), the European Savings and Retail…
September 7, 2022
EU Taxonomy minimum safeguards: Criteria for the application of external checks should be further defined
The European Savings and Retail Banking Group submitted its final response to the Platform for Sustainable Finance (PSF) consultation on its draft report on minimum safeguards (MS). In its response,…
August 3, 2022
International Sustainability Standards Board consultation on Sustainability Disclosures
The International Sustainability Standards Board (ISSB) has been established at COP26 with the purpose of developing a comprehensive global baseline of sustainability disclosures for the capital…
July 8, 2022
World savings and retail banks call for harmonised taxonomies on sustainable finance
The World Savings and Retail Banking Institute (WSBI) called today on policymakers for the harmonisation of taxonomies on sustainable finance. At the end of the 26th WSBI World Congress, the…
July 7, 2022
World savings and retail banks moving forward on sustainability
World Savings and Retail Banking Institute (WSBI)'s members get together for the first time since 2018 at the 26th World Congress, in Paris. Under the title 'Locally Rooted, Globally responsible' the…
May 27, 2022
ESBG calls for more feasible rules on the new corporate sustainability due diligence
In its response to the European Commission call for feedback on the proposal for a Directive on Corporate Sustainability Due Diligence, the European Savings and Retail Banking Group (ESBG) suggests…