Proportionality as the Core Principle of the Supervision of a Heterogeneous Banking Sector Lessons Learned From Germany with an heterogeneous banking sector.

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Presentation transcript:

Proportionality as the Core Principle of the Supervision of a Heterogeneous Banking Sector Lessons Learned From Germany with an heterogeneous banking sector of roughly 2,000 banks Dirk Kramer Federal Financial Supervisory Authority (Germany) (Bundesanstalt für Finanzdienstleistungsaufsicht; BaFin) EBA Workshop „The application of proportionality measures in the EBA‘s regulatory work“ London, October Proportionality – Regulation & Supervision | 22.October.2013 | Page 1

Background Heterogeneity of the German financial system (roughly 2,000 institutions varying by size, complexity, business model, etc.) Our understanding of Pillar 2 requirements Qualitative proportional requirements Focus on organisational structures & processes Recognition as a management tool for banks Long-term experience with qualitative supervision Proportionality – Regulation & Supervision | 22.October.2013 | Page 2 Proportionality / Regulation & Supervision (I)

Concept of Proportionality within Pillar 2 regulation & supervision Can we precisely (and practically) define proportionality? Do we need clear-cut thresholds resulting in automatism?  appealing but have their drawbacks Alternative concept: principle based regulation with a “basic rulebook” Wide scope: for all credit institutions and investment firms Comprehensive: addresses main risk management issues (requires only few further regulations/guidelines) Banks are responsible for the implementation depending on nature, scale and complexity of the banks and their activities In Germany: the Minimum Requirements for Risk Management (MaRisk) ≈ EBA GL 44 + few further issues Proportionality / Regulation & Supervision (II) Proportionality – Regulation & Supervision | 22.October.2013 | Page 3

Categorisation & On-site Inspections in 2012 Source: BaFin. Annual Report 2012 (Table 19/p. 141) Proportionality – Regulation & Supervision | 22.October.2013 | Page 4

Our Recommendation We should further elaborate the EBA Guidelines on Internal Governance (GL 44) as the central basis of Pillar 2 requirements within the European Single Rule Book! More granularity (not rule based) A flexible guideline for categorisation with case-by-case decisions Integrate other guidelines, i.e. increasing the scope Proportionality – Regulation & Supervision | 22.October.2013 | Page 5

Thank you very much for you attention Dirk Kramer (Section BA 54: Proportionality – Regulation & Supervision | 22.October.2013 | Page 6

Appendix I: Supervision Pyramid It is the task of supervisors to challenge institutions on a case-by-case basis to implement the requirements – with MaRisk as the benchmark. Final responsibility for prudential supervision by BaFin, in close cooperation with Deutsche Bundesbank Off-site supervision by using various information sources for daily supervision and risk assessment; including the auditors long form report as a central element special audits (sect. 44 Banking Act) by Deutsche Bundesbank and external auditors Internal controls and risk management of the institutions Proportionality – Regulation & Supervision | 22.October.2013 | Page 7

General Requirements Issues such as: internal capital adequacy process (ICAAP), risk-inventory, strategies, documentation, stress testing, human- and technical resources, outsourcing, activities in new products/markets, … Special Requirements for the Internal Control System Requirements for the structural and operational arrangements Requirements for processes for risk control: Special Requirements for the Internal Auditing Function Lending business Trading business Counterparty risk Market price risk Liquidity risk Operational risk Appendix II: Modular Structure of MaRisk Proportionality – Regulation & Supervision | 22.October.2013 | Page 8