Yes, it is adequate to use the same data as used in the BCBS identification process of scoring because the EBA’s list will not diverge from the FSB’ list, but we request the homogenous application of the Basel 3 rules all around the world in order to avoid discrepancies between institutions.
An assessment of the impact of this divergence should be performed to see if there is an impact on the banks’ classification in the buckets.
Yes, the indicators are quite relevant, but some comments could be made. The main criticizes are:
1. That almost all criteria retained by the BCBS are an expression of the size whereas this indicator is already taken into account by the leverage ratio and the capital ratio framework. Moreover, the size of the bank is taken into account twice in the asset size indicator and in the complexity indicator (i.e.securities).
2. The cross boarder activities are considered as systemic indicator whereas a geographical diversification is the reflection of a base of sound risk management practices.
3. An adaptation of the definition of the cross border activity indicator (Article 131-e) is necessary to be in line with the strengthening of the European Monetary Union. We suggest defining the Eurozone as a domestic market. It should be consistent with the Banking Union building. The EBA's proposal creates artificial cross-border activity as compared to US banks operating in different
We request to synchronize the disclosure of the indicators by the banks and the list of global systematically important institutions (G-SII), in order to avoid confusion for investors and analysts (i.e November).
Due to a lack of precision in the ITS, we are in favour of the public disclosure of the indicators only.
The template provided by the EBA should be completed with cross references in the Excel spreadsheet, related to other reporting templates and a “memo” from the supervisor should be drafted to provide the same guidelines to all banks (i.e. the classification of economic agents). This way, the process would be more robust, as an auditable process should be.