The members of the EACB welcome the opportunity to comment on the EBA draft Guidelines on the supervision of significant branches.
Improving the convergence of supervisory practices between home and host supervisors is of the utmost importance in a time of heightened regulatory and economic uncertainty. Moreover, a clear framework for the identification of significant branches by host authorities would allow institutions to form solid expectations and develop consistent practices.
We would like to highlight that branches have no independent legal personality or separate legal status and they form integrally part of their mother company, differently from subsidiaries. Being integrated within the supervisory framework of the credit institution of which they are a part, they should continue to be subject to specific supervision as such. This exercise should rather help in clearly determining the scope of the branches subject to host supervision and, and optimizing, if not minimizing, the burden that host authorities may impose on branches.
Finally, supervisory dialogue with institutions must remain central. In addition to the use of quantitative criteria, exchange between institutions and competent authorities shall be key to determine if a branch is to be considered significant or not. We suggest to include in the GL a clarification in this respect.