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Polish Bank Association

It is difficult to accept the proposal of regulation where the advanced economies are limited to the euro area and markets of Denmark and Sweden among the EU members. We do not understand and we do not accept the division of the EU markets when we have principle of one licence on the financial markets in the EU. The stocks listed on the stock exchanges in the euro zone countries are also listed on the market in other markets in the EU countries. This artificial division of market proposed in the draft regulation creates the question concerning the treatment of the stock which are listed on the stock exchanges in different EU member states.

We can also compare the capitalisation, turnover on the stock exchange in Poland with the capitalisation, turnover of the stock exchanges in some euro zone member states. We are convinced that the indicators for Polish market are not worse than for some euro zone member states.
We have similar approach concerning the economic development in the EU member states. The present economic results of Poland are below the average level in the EU, but many indicators of macroeconomic situation, for example the public debt /GDP are more conservative than in many euro zone member states. If we observe the GDP per capita using the real value of this GDP (including the different level of prices in Poland and some euro zone member states) we do not see so big differences which may be the justification for exclusion some EU member states being outside euro zone from the proposed list of advanced economies. We would not name the countries in the euro zone where the economic situation in worse than in Poland and they would benefit the status of the advanced economies.

We can mention also the level of credit rating granted by the top rating agencies to the debt of different member states in the EU. We can easy find that the credit rating of the Polish debt is higher than the rating of some euro zone member states.

Finally, we strongly recommend not to divide the EU member states for purpose of application of risk weights in market risk and establish the same status for all EU member states. There is no economic reason to divide the EU member states in this way. In our opinion this division has very limited economic background. We do not understand why some market more privileged than others, particularly when the banking union is not finished and the euro zone debt is not really common.
Some general proposal for additional metrics were presented in answer to question 1. These indicators should be explored by the EBA in order to adapt the proposal of draft regulatory technical standards to real economic situation in the different EU member states. The accompanying documents to the EBA draft regulatory technical standards does not include any justification in numbers and metrics to explain the choice of the market treated as the advanced economies. There is the reason why is not necessary to define alternative criteria but we recommend check carefully the criteria proposed in the draft of regulation.
We believe that the market in Poland is characterised by a similar liquidity/ volatility if compared to some markets of the countries listed in Article 1. There is the reason to recommend to join the Polish market to the list of advanced economies as it should not trigger a higher risk-weight in comparison to those of the countries listed in Article 1.
Polish Bank Association