-In this
position paper the
ESBG explains some reservations concerning the timing of the proposed directive and also makes political and technical remarks that are as follows:
Supplementary prudential rules for financial conglomerates should be coherent with regard to the results of the Basel Committee’s Qualitative Impact Study II as well as the revision of the International Accounting Standards (IAS).
The proposed directive should only be implemented when binding standards are laid down also at international level. By imposing additional capital adequacy requirements, reporting rules and internal control mechanisms on banks within the EU, the proposed directive would place these banks at a disadvantage compared to their competitors outside the EU.
The deduction rule suggested in the proposed directive would significantly infringe the existing sectoral supervisory rules.
The ESBG opposes the provision that only cross-sector capital was allowed to be used for the additional solvency requirements for financial conglomerates.
The 10 % threshold to determine whether cross-sectoral activities are significant should be raised to at least 15 %. In addition, a minimum threshold of a balance sheet total of 150 billion Euros should be introduced.
At the same time should the 50 % threshold to determine whether the activities consist mainly in providing financial services, be lowered to 40 %.
© European Savings Banks Group
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