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.
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.
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).
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).
This seems a good practice but will probably not be relevant for Belgium as Belgian banks will have reached the target quite rapidly.