Also for internal model investigations, ESBG writes in response to ECB consultation on OSI-IMI draft guide
>> See ESBG response to consultation
BRUSSELS, 18 July 2017 – Higher transparency is welcome in the ECB’s agenda when pursuing on-site inspections (OSI) and internal model investigations (IMI), savings and retail banking association ESBG argued in its response to the central bank consultation on its OSI-IMI guide.
In its response submitted last Friday on the draft guide – which explains how the ECB’s banking supervision arm conducts inspections and provides a useful reference document for banks subject to such inspections – ESBG noted that higher transparency in the ECB agenda would allow for better internal organisation and resource allocation by the inspected banks, especially in the case of specific recurrent inspections.
ESBG also responded to other aspects of the guide, calling, whenever possible, for a few weeks’ notice before the commencement of an inspection. They see the need to set limits for information requests under specific circumstances, first and foremost when such information is already available within another unit of the ECB or a National Competent Authority (NCA). Also, they see the possibility for each supervised institution to choose the senior representative for the kick-off meeting.
They also advocate for a reformulation of the follow-up phase: no measures should be applied to the inspected institution in case it doesn’t implement the action plan stated by the supervisor in its follow-up letter, as such action plan reflects non-binding expectations.
In the ESBG response, the association also advocates for:
The bilateral definition of deadlines for what concerns data, information and meeting requests;
Guaranteed data protection standards;
A formal time framework stating at least the average and maximum duration of inspections;
More transparency in the selection of the external consultants in support of the OSIs missions.