Deutsche Bank

Yes the scope of the guidelines are appropriate given the tasks laid out in Article 11.
The current scope of the mapping process is proportionate capturing the main entities that will create risk within a financial conglomerate.

Where a legal entity mapping process has not been undertaken previously, this activity can be time consuming. The mapping process should be completed prior to the meeting on supplementary supervision of the financial conglomerates or the relevant sectoral college. This will ensure that the coordinator and the other competent authorities are not distracted from the main task of assessing the risks arising from a financial conglomerate structure.
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.
In general, we expect that for a financial conglomerate the costs for responding to information requests and interacting with the regulator will already be borne and hence these requirements are unlikely to lead to a change in costs. We make some further suggestions below that will limit any increase in cost.
Matthew Nash
D