Response to consultation on guidelines on criteria to to assess other systemically important institutions (O-SIIs)
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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
Question 2: Do you agree that there may be Member States where small institutions are unlikely to pose systemic threats to the domestic economy? Do you think the option to exclude these institutions could reduce the administrative burden for institutions, or do you think there is a risk that the results of the analysis could be distorted by excluding them?
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.Question 3: Can you think of any additional optional indicators that should be added to the list in Annex 2?
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