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Response to consultation on revised Guidelines on stress tests of deposit guarantee schemes
Go backQuestion 1: Do you have any comments on the proposals to address the issues of the definitions, the test formats, the use of granular tests and the arrangements to ensure objectivity?
The Swedish National Debt Office (SNDO) supports that the particular set up of the DGS should be taken into account when making arrangements to ensure objectivity (paragraph 15).
For the SNDO the Risk unit is responsible for independent and overall monitoring of the authority and its activities. The unit is also responsible for overall reporting to the management team and board. Therefore, the set up for the SNDO is that the Risk unit is involved in the stress testing process to ensure objectivity. Mandatory use of an external auditor/consultancy firm is not a preferred option as the SNDO has the relevant competence and resources in house and as it would increase costs for the DGS.
Question 2: Do you have any comments on the proposals to increase the complexity of stress tests (as provided in Guideline 4.109), retest the aspects impacted by significant changes in DGS’s systems and processes (Guideline 3.4), and require stress testing all the legally mandated functions of a DGS (Guideline 3.2)?
No comments. Question 3: Do you have any comments on the grading of the outcomes (as proposed in Guideline 5), the deadline for the next report submission (Guideline 6.2), the reporting of the area not required by the Guidelines and the background information on the DGS to fill in the revised reporting template?
No comments. Question 4: Do you have any comments on the proposals to address the issues related to the design, execution and reporting of SCV files stress tests, in particular the differentiation into two categories of SCV files stress tests (as proposed in Guideline 4.7), stress testing the SCV files of all relevant institutions (Guideline 4.9), and the definition of substandard entries (Guideline 4.19)?
No comments. Question 5: Do you have any comments on the proposals on the assessment of the IT safety (as proposed in Guideline 32), stress tests of reimbursing depositors in complex cases (Guideline 48 and 49) and selection of DGS partner when stress testing cross-border cooperation (Guideline 4.51)? Do you have any further comments on the design, execution and reporting of operational capability tests?
Considering that a full report from assessing the IT safety could include detailed sensitive information, the SNDO supports the proposal that the DGSs only should report the main conclusions. Question 6: Do you have any comments on the proposals on stress testing the adequacy of the funding means for each affiliated credit institutions (as provided in Guideline 4.65), stress testing the access to all of DGS’s funding sources (Guideline 4.72) and stress testing the governance framework of the funding means (Guideline 4.70)?
No comments. Question 7: Do you have any comments on the proposals to address the issues related to the design, execution and reporting of stress tests related to contribute to resolution, failure prevention and contribution to insolvency proceedings (as provided in Guideline 3.27, 4.84 and 4.92)?
No comments. Question 8: Do you have any other comments on the proposed revised guidelines on stress tests of DGSs?
N/AName of the organization
Swedish National Debt Office
