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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.