Response to consultation on draft revised guidelines on methods for calculating contributions to deposit guarantee schemes
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We suggest trying to limit the national discretion in order to obtain more level playing field over the different Member states.
We would object the possibility for national DGSs to set stricter threshold (example for clarification: lowest threshold of 5% instead of 3% for the leverage ratio, meaning that more banks get a more negative risk score).
The use of the sliding scale method seems fairer but is far more complex and creates undue complexity and unpredictability (also referring to a similar use for calculating contribution to the Single Resolution Fund).
General comments
Febelfin welcomes the EBA consultation.Question 3: Do you have any comments on changing the reference from the ‘annual’ calculation of contributions to the ‘periodic’ calculation of contributions and on the clarification to set the periodic target level in section 4.2 of the Guidelines?
We are not in favour of the possibility of giving DGSs the possibility to levy contributions periodically since this would increase the administrative burden for the banking sector.Question 7: Do you have comments on the proposed changes to the minimum weights of core indicators and the maximum weight of any indicator, as set out in section 4.5 (ii) of the Guidelines?
This could have a substantial (or no ?) impact on the existing methodology (local legislation on distribution remaining 25% following the updated distribution from the EBA).We suggest trying to limit the national discretion in order to obtain more level playing field over the different Member states.
Question 9: Do you have comments on the proposed minimum thresholds for the IRS of some core indicators, as set out in section 4.5 (iii) of the Guidelines?
It is not clear how this works out in practice.We would object the possibility for national DGSs to set stricter threshold (example for clarification: lowest threshold of 5% instead of 3% for the leverage ratio, meaning that more banks get a more negative risk score).
Question 10: Do you have comments on the proposed changes to the formula for translating the ARS into the ARW, as set out in section 4.5 (v) of the Guidelines?
We would not object the new mathematical bucket method with constant ARW multiplier.The use of the sliding scale method seems fairer but is far more complex and creates undue complexity and unpredictability (also referring to a similar use for calculating contribution to the Single Resolution Fund).