The members of the EACB welcome the opportunity to comment on this Commission’s initiative seeking input on the EU macro-prudential framework.
In our view it is very important to ensure, that decisions taken in individual EU Member States are in line with the objective of a level playing field and equal treatment, and particularly urgent in the light of the ESRB report from May 2016 on macro-prudential policy measures implemented and notified by national authorities, where a sharp increase can be observed in activated or planned macro-prudential measures over 2015.
Particularly for cross-border banking groups, there is a risk of inconsistencies in the application of the current macro-prudential framework. For instance, significant differences can be noticed regarding the application of the systemic risk buffer in terms of level, reasoning, affected institutions and phasing-in etc.
Aligning the interplay of measures, procedures and the institutional setting in a comprehensive manner is of key importance to avoid duplications and overlaps in addressing the same risk. Also the transparency of decisions taken by national authorities should be increased.
Examples of actions that could contribute to streamline and enhance the framework are:
- The establishment of an ESRB guide for sound decision-making in the setting of the individual macro-prudential measures (level, risks addressed by which tool, pecking order).
- The evaluation of the role of the ECB with coordination powers for macro-prudential tools for the Eurozone.
- A clear and comprehensive justification by the authority on the use of macro- prudential tools.
24 October 2016
European Commission consultation on the Review of the EU macro-prudential policy framework - EACB comments
EACB