The members of the EACB welcome the opportunity to comment on the Commission exploratory consultation on the finalised Basel III framework. We appreciate the intention to open a first channel for feedback even before launching the data collection and the process of drafting a legislative proposal.
Given the complexity of the revisions and the far reaching consequences of the proposed changes, we would very much welcome if the Commission maintained an open and continued exchange with the industry. In particular, the institutions will be assessing the impacts of the Basel deal over the coming months and criticalities in connection with EU specificities may be identified at any stage.
We would also like to recall that the EBA already indicated in its first assessment from 20th December 2017 an increase in capital requirements resulting from the final deal of roughly 13% on average (almost 15% for IRB banks). This is not only above the long stated objective of an average capital increase not greater than 10%, but also suffers from a number of data limitations and does not reflect the situation of Member States where the increase is likely to be even above 20%. In this context we encourage the Commission and the EBA to proceed to a careful and wide ranging data collection and impact assessment that is not the mere result of the transposition of Basel templates. It should take into account, for instance, targeted sectoral (real estate, SMEs, agricultural lending, corporate lending, trade and commodity finance) and regional analysis of impacts and provide sufficient time to allow the largest possible number of banks to participate in the exercise.