EACB position paper on ESA's capital calculation methods for financial conglomerates

EACB welcomes the introduction of uniform conditions relating to the calculation of the required capital at the level of financial conglomerates, taking into account the expected come into force of CRD IV - CRR I and Solvency II and the consequent need for adaptation at the level of legislation for financial conglomerates. We consider it desirable to develop common rules for calculation of solvency of financial conglomerates that will maintain the level playing field in the European Union. We note, however, that the requirements proposed by the draft RTS go far beyond the provisions of the Financial Conglomerates Directive (FiCoD) and introduce a new level of standards (cross-sector and sector-specific capital, as well as new requirements on capital transferability). We acknowledge that appropriate consideration to the changes in the sectorial rules should be given, but the substance of FiCoD should not be changed – FiCo requirement should remain a minimum requirement. Moreover, the draft RTS should not raise any level playing field issues between banking-led and insurance-led financial conglomerates in particular, as capital serves the same purpose in both sectors