CEBS publishes paper on implementation issues relating to the CRD

CEBS is today publishing a paper on the range of practices with respect to various implementation issues relating to the Capital Requirements Directive (Basel II implementation issues) which have specific cross-border relevance.

CEBS focuses on providing advice on the implementation and practical application of Community legislation and CEBS guidelines, and fostering practical convergence in the day to day application of such legislation and guidelines to cross-border business. In the past year CEBS has been significantly involved in collecting and analysing Basel II implementation issues that cross-border banking groups and their supervisors believe to be the most challenging from a cross-border perspective. Some of the issues have directly been raised by the Industry Platform on Operational Networks; others have been raised by supervisors from the experience they have gained so far.

This paper looks into the most important issues analysed so far. This paper should be viewed as an additional contribution regarding the work of CEBS concerning implementation issues, and is in line with other mechanisms of CEBS promoting practical convergence. For some of the issues mentioned in the paper a concrete answer is provided, while for other issues a catalogue of pragmatic approaches is presented which, on the basis of the current experience both of supervisors and banking groups, appear broadly consistent.

The approaches reported in this paper are real-life examples of specific applications of the CRD and CEBS guidelines to the banking groups represented in the sample of banks participating in the work of CEBS regarding operational networking. Therefore, they should not be taken to be generalized solutions nor be read by institutions as a limitation on the identification of approaches which may be better suited to their specific needs.

CEBS will continue to address issues arising from implementation of the EU banking legislation and CEBS Guidelines in a cross-border setting in order to refine the analysis undertaken so far and propose pragmatic solutions to other issues that will be raised by cross-border groups and their supervisory colleges. In certain areas where the work done has not yet been successful in reaching the desired level of convergence, CEBS is committed to further work in this direction, including using a structured query mechanism.