Summary of online survey on contributions

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1 Summary f nline survey n cntributins Frm June 20 th t July 14 th an nline-based cnsultatin was pened fr feedback n key questins cncerning the legal acts fr cntributins f credit institutins t reslutin financing arrangements under the Bank Recvery and Reslutin Directive 2014/59/EU (28 natinal reslutin funds in BRRD) and the Single Reslutin Mechanism (SRF, the Single Reslutin Fund fr the Banking Unin). There were 3,609 replies in that survey which was pen t everyne. Out f thse respnses were frm individuals. Based n an analysis, many f thse individuals used an identical r very similar text when prviding cmments. Of the remaining 1 f respnses, 9 f respnses came frm credit institutins (with cperative banks frming the large majrity), 8% frm rganisatins and frm public authrities. Abut 85% f respnses frm nn-individuals came frm German residents and abut 5% frm Austrian residents. Abut half f all respnding credit institutins had a balance sheet size f at r belw EUR 300 millin and a further 3 had a balance sheet size f belw EUR 1 billin. Only abut 5% had a balance sheet size in excess f EUR 10 billin. Mst individuals did nt prvide an address. The fllwing prvides a summary f the respnses, gruped by categries f respndents. The first questin asked whether the cntributins shuld be calculated using individual r cnslidated data. f ttal respnses pted fr the individual level and the agreement is bradbased amng all categries f respndents. Percentage f respndents favuring the calculatin f cntributins based n individual data vs. cnslidated data. Percentages might nt add up t 100 due t runding r respndents nt replying t the questin. Ttal Credit institutins Public authrity Organisatins Individuals individual cnslidated 29% The secnd questin asked if small credit institutins shuld be treated in a special manner, cmpared t what they wuld pay n the basis f a general frmula that wuld apply t all credit institutins. In this categry f ttal replies agreed with such a special treatment and the agreement was brad-based amng all categries f respndents. Percentage f respndents agreeing t treat small credit institutins in a special manner. Percentages might nt add up t 100 due t runding r respndents nt replying t the questin r prviding n pinin. Ttal Credit institutins Public authrity Organisatins Individuals agree 5 1

2 disagree 18% The third questin addressed the weight f the flat cntributin and asked if it shuld be prminent r if the risk-adjustment part shuld be prminent instead. In ttal, replied that the risk-adjustment shuld be the mst prminent part f the cntributin with a brad based agreement amng all grups, except fr public authrities which were evenly split n that issue. The mst prminent part f the cntributins shuld be the Percentages might nt add up t 100 due t runding r respndents nt answering the questin Ttal Credit institutins Public authrity Organisatins Individuals flat part 5 18% risk part 5 6 The frth questin asked if Stakehlders agreed with a series f specific pillars and indicatrs, asking t specify their degree f imprtance. Regarding the pillar "Risk expsure" f replies agreed with the imprtance f this pillar, with 9 assigning a high imprtance. Bth the agreement and the assessment f the risk pillars' imprtance are high amng all categries f respndents. Cncerning the indicatr RWA/Ttal Assets (+) f ttal replies agreed with the indicatr and assigned a high imprtance t it. With the exceptin f respnding public authrities and rganisatins, agreement t that indicatr is lw amng all categries f respndents. Regarding the indicatr Capital rati (-) f ttal participants agreed with this indicatr and felt that it wuld be highly imprtant. Bth the agreement t this indicatr and the perceptin f its imprtance are brad-based. Fr the Leverage rati: Tier 1 Capital ver Ttal Expsure Measure, f ttal participants agreed with this indicatr with 9 placing high imprtance n it. Agreement t this indicatr is brad-based as is the perceptin f its imprtance. Regarding the Rati f bail-in-able funds available in excess f the minimum requirement fr wn funds and eligible liabilities (-), f respndents agreed with the indicatr and a attached a high imprtance. Bth the agreement t this indicatr and its perceived relative imprtance are lw acrss all categries f respndents. 2

3 Risk indicatr pillar and crrespnding indicatrs: Questins: D yu agree with the risk pillar/indicatr? Is the risk pillar/indicatr imprtant r nt imprtant? Percentages might nt add up t 100 due t runding r respndents nt answering the questin. Ttal Credit institutins Public authrity Organisatins Individuals Pillar: risk expsure agree 9 imprtant % 5 nt imprtant 4% 9% % RWA/ttal assets 7% 9% 35% 9 79% Capital rati 9 6 5% 24% 9 5 Leverage rati 9 89% 3 8% Rati f bail-inable funds in excess f minimum required rati 5% 7% 2 2 On the pillar Stability and variety f the surces f funding f ttal replies agreed with this pillar and placed a high imprtance n it. These patterns f respnses were cmmn amng all categries f respndents. 3

4 Fr the indicatr Lan-t-Depsit Rati: all lans except lans t credit institutins/depsits (+) 9 f ttal participants agreed with this indicatr but 9 f all respndents assigned t it a lw level f imprtance. The pattern f respnses is similar acrss all categries. Regarding the Liquidity Cverage Rati, f participants agreed with this indicatr but 9 placed lw imprtance n it. Funding pillar and indicatrs: Questins: D yu agree with the risk pillar/indicatr? Is the risk pillar/indicatr imprtant r nt imprtant? Percentages might nt add up t 100 due t runding r respndents nt answering the questin. Ttal Credit institutins Public authrity Organisatins Individuals Pillar: Funding agree 67% 65% imprtant 85% 5 35% nt imprt 2 lant-depsit rati 9 89% % Liquidity Cverage Rati 9 8% % 5 29% Fr the pillar Imprtance f an institutin t the stability f the financial system r ecnmy, f participants agreed with this pillar and replied that the pillar wuld be highly imprtant. As regards the indicatr Ttal Cnslidated Assets at Eur Area level/eur Area GDP (Member State GDP fr credit institutins in Member States nt participating in the Banking Unin) (+) f participants agreed with this indicatr and thught it was imprtant. Only public authrities and rganisatins agreed with the indicatr and attached a significant imprtance t it. 4

5 On Expsure t ther credit r financial institutins when cmpared with the verall financial sectr (+) f ttal replies agreed with this indicatr but 94% assigned a lw imprtance. Systemic imprtance risk pillar: Questins: D yu agree with the risk pillar/indicatr? Is the risk pillar/indicatr imprtant r nt imprtant? Percentages might nt add up t 100 due t missing answers, but als due t runding. Ttal Credit institutins Public authrity Organisatins Individuals Pillar: systemic imprtance agree imprtant 9 67% 5 65% nt imprtant 9% Assets t GDP % Expsure t financial sectr 94% 5 18% Next t the standardised questins, the survey als prvided the pssibility t cntribute with additinal remarks. Sme respndents transmitted separate dcuments, indicating that thse shuld be read in cnjunctin with their replies. Sme suggested that the imprtance f an institutin t financial stability shuld be an verriding factr fr setting cntributins. Als mentined were the institutin's reslutin strategy, its prbability f failure, likelihd f being placed in reslutin in an event f failure and the prbability f lsses fr the reslutin fund. Sme suggested that large internatinally active banks, with their intercnnectedness and whlesale market dependence, shuld pay mst f the cntributins. Many respndents suggested that small reginal r retail riented banks r banks being members in an IPS (Institutinal Prtectin Scheme) wuld nt be risky and shuld therefre cntribute little r 5

6 nthing (lump sum allwance r de-minimis clause). In cntrast, thers cnsidered that the failure f small banks culd have an impact n financial stability. Sme stated that IPS membership shuld nt in itself be a reasn fr lwer cntributins because an institutin might be s big that it might stretch the IPS t its capacity limits. Very few respndents indicated that natinal specificities shuld be cnsidered fr the treatment f small banks and very few requested that the small bank treatment shuld be als applied t investment firms. Sme suggested excluding intragrup liabilities frm the calculatin base, while thers were ppsed. One respndent explained that calculating cntributins at the highest level f cnslidatin wuld avid duble cunting. Very few respndents als mentined the need t ensure a level playing field by treating intragrup liabilities equally, regardless f whether they wuld be inside r utside the Banking Unin. Very few respndents suggested excluding intra IPS liabilities. Sme suggested excluding prmtinal lans and very few favured excluding Danish mrtgage banks frm the cntributins, r treating develpment banks different. Very few suggested excluding CSDs and CCPs (but als custdian r settlement banks) r treat them in a special way. Very few suggested t net derivatives when based n legally binding netting agreements. Instead f giving a prminent functin t the flat r the risk part f the cntributins, sme suggested that bth elements shuld feature in a balanced way. Others explained that their preference fr a predminance f the flat part wuld ensure predictability f the cntributin size. On the indicatrs themselves, sme respndents explained that risk weighted assets (RWA)/ttal assets wuld advantage banks with efficient internal risk-based mdels. Others cnsidered that indicatr as an adequate measure f risk expsure. Very few suggested that the indicatr ttal assets t grss dmestic prduct (GDP) wuld duble cunt size, next t the criteria used fr the flat cmpnent f the cntributins. It was stated that the leverage rati wuld reflect risk expsures and captures the imprtance f trading activities and ff-balance sheet expsures. Others disagreed and stated that the indicatr wuld nt take the risk-intensity f assets int cnsideratin. Very few respndents suggested adding indicatrs such as an evaluatin f the supervisry authrity r the reslutin authrity as regards cmplexity and reslvability, the share f banks' capital market financing, and as regards membership in an IPS. Sme suggested adding the net stable funding rati as an additinal indicatr next t the liquidity cverage rati and instead f the lan-t-depsit rati, as this indicatr wuld nt adequately reflect differences in funding structures acrss banks. Very few respndents als suggested adding an indicatr fr nn-perfrming lans. Very few respndents suggested that the risk indicatrs shuld be aligned with already existing risk indicatrs used by ther institutins r used fr ther purpses. Very few suggested intrducing a natinal cap fr the cntributins t the SRM fund t prevent distrtins between banking sectr structures f the Member States. 6

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