Response to joint Consultation on the Guidelines on the convergence of supervisory practices relating to the consistency of supervisory coordination arrangements for financial conglomerates

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3. Do you consider appropriate the minimum number of meetings described in paragraphs 49 and 50?

We agree that at least one physical meeting per annum is sufficient to ensure supervisors effectively assess the risks from a financial conglomerate without causing unnecessary burden to the firm.

To make the meeting effective we suggest that a standardised agenda be prepared at least six weeks in advance of the meeting to provide sufficient time to prepare the necessary information.

Furthermore, we support the intention of the BCBS under their good practise principles for colleges that colleges should enhance information exchange and cooperation on an ongoing basis. Such ongoing dialogue on group risks is more likely to deliver on the objectives of the college than the periodic ‘set piece’ meetings. As such we support a proportionate approach to regular and standardised information flows that will complement physical meetings.

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Name of organisation

Deutsche Bank