The National Bank of Romania has no proposal for new mandatory indicators. We consider that the agreed mandatory indicators are sufficient to evaluate the systemic importance of credit institutions on markets which are relevant from the financial stability perspective (banking assets, loans, deposits, payments, derivatives, cross-jurisdictional assets and liabilities, interbank assets and liabilities, debt securities).
The National Bank of Romania agrees that there may be MS where small banks are unlikely to pose systemic risks. We consider that the option to exclude these institutions should be subject to national flexibility, taking into account that the structure of national financial systems across MS is heterogeneous. Given that the EBA methodology provides for a virtual entity having a value which compensate for the exclusion of the small banks, we consider that the results will not be distorted in this specific case.
The National Bank of Romania proposes the following optional indicators that would enable a thorough analysis of potential systemic risks sources that might result from the specificities of the Romanian financial system:
1. Sectoral breakdown of loans granted to non-financial companies (according national statistic classification NACE)
2. Non-financial company’s loans breakdown by currency
3. Non-financial company’s loans breakdown by residual maturity
4. Non-financial company’s loans breakdown by collateral type
5. Non-financial company’s loans breakdown by product type (treasury, investments, equipment, loans for foreign trade financing etc.)
6. GVA generated by the non-financial companies with loans
7. Number of employees of non-financial companies with loans
8. Trade activities of non-financial companies with loans
9. Deposit structure by currency
10. Deposit structure by maturity
11. Transaction values on government securities market
