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In response to the current consultation, the NVB asks the Commission to take note of the following points:
o The DGS is not meant to serve as an instrument to prevent or manage a crisis.
o It can only be seen and used as a safety net for small failures after all other supervisory (and liquidity) tools have proved powerless to prevent such a failure. A DGS is there to protect small retail depositors;
o Before making major changes to any DGS a proper impact assessment should be performed. Some of the questions posed in this consultation can’t be answered in advance, since the implications are not known;
o Strong effective pro-active (prudential) supervision as part of the overall safety net is of utmost importance. Any DGS can only be seen as an integral part of this safety net and should also be well aligned with the crisis-management framework and the rules as to burden-sharing;
o The DGS has performed well in the past. Making major changes to the current framework, just as depositors have grown accustomed to the national DGS, could create instability and reduce depositor confidence. This should be prevented at all costs;
o Banks are faced with a full regulatory agenda including multiple amendments to the Capital Requirements Directive (CRD). While acknowledging the need for review of the DGS Directive, we underline the need for prioritisation and proper alignment of all the proposals that are planned.