The German deposit guarantee schemes (the National Association of Cooperative Banks (BVR), the German Savings Banks Association (DSGV) and the Compensation Scheme of German Private Banks (EdB)) are pleased to note that the revised guidelines on risk-based contributions (...) maintain the basic methodology for contributions and make only technical amendments. We have no further comments to make on this.
It is essential, however, that the German deposit guarantee schemes are given sufficient time to implement the guidelines. We believe it is appropriate for the guidelines to apply to the banks’ annual financial statements from 1 January 2024 at the latest. The date of application under 3(12) should therefore read as follows, “These guidelines apply to the annual financial statements of institutions from 1 January 2024”.
This assumes that the guidelines are still published in the first quarter of 2023. The background for allowing a sufficiently long implementation period is that there is no certainty as to what the new guidelines will be until they are published. Only then can the deposit guarantee schemes begin implementing them. The deposit guarantee schemes need around six months to implement and fine-tune the procedural and technical requirements of the guidelines.
However, the process of collecting contributions for the German deposit guarantee schemes begins in the second quarter of each calendar year. Assuming the revised guidelines are published in the first quarter of 2023, it will no longer be possible to apply them in the 2023 calendar year.
In addition to which, the CRR credit institutions covered by the German deposit guarantee schemes will also require sufficient lead time.