Main features of the method for the identification of other systemically important institutions (O-SIIs)
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1 Main features of the method for the identification of other systemically important institutions (O-SIIs) Status: July 2016
2 Main features of the method for the identification of other systemically important institutions (O-SIIs) Basis for identifying O-SIIs The identification of other systemically important institutions (O-SIIs) in Germany is governed by section 10g (2) of the German Banking Act (Kreditwesengesetz KWG) and is consistent with the guidelines of the EBA (European Banking Authority) on the assessment of other systemically important institutions (EBA/GL/2014/10), which, in turn, take into account the framework of the BCBS (Basel Committee on Banking Supervision) for the treatment of domestic systemically important banks. The German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht BaFin), in agreement with the Deutsche Bundesbank, identifies at least annually which institutions should be classified as O-SIIs. To this end, the Bundesbank and BaFin have jointly developed a method that is based on section 10g (2) of the KWG and takes into account the principles-based requirements of the BCBS as well as the EBA/GL/2014/10 guidelines which have been applicable since 1 January The approach for the identification of O-SIIs comprises two steps. In Step I, the institutions are initially evaluated according to a standardised indicator-based scoring model developed by the EBA in order to ensure that O-SIIs are identified on a comparable and transparent basis in all EU member states. In Step II, national supervisory authorities may classify further institutions as O-SIIs ( supervisory assessment ). This scope for discretion on the part of national supervisory authorities is intended to ensure that greater allowance can be made for specific aspects of the respective national banking system. Step I: Scoring model with EBA standard indicators In Step I, the EBA s standardised indicator-based scoring model calculates an overall score for each institution. The scoring model applies indicators from the following categories: size, economic importance for the European Economic Area (EEA) and Germany, cross-border activity and interconnectedness with the financial system (see Table 1).
3 Table 1: Indicators for identifying other systemically important institutions Category Step 1: Mandatory Step 2: Nationally expanded indicators indicators Size Total assets Total assets + contingent liabilities Economic importance Value of domestic Number of indirect (including payment transactions participants connected via substitutability / Private sector Target2 financial system deposits from Value of domestic infrastructure) depositors in the EU payment transactions Private sector loans processed for non-banks to recipients in the Number of domestic EU payment transactions processed for non-banks Private sector deposits in Germany Private sector loans in Germany Cross-border activities Cross-jurisdictional Claims from foreign nonbanks (including complexity) liabilities Cross-jurisdictional Liabilities to foreign nonbanks claims Notional value of OTC Claims from foreign banks derivatives Liabilities to foreign banks Number of legally independent subsidiaries in Germany and abroad Receivables from derivatives in trading portfolio Liabilities from derivatives in trading portfolio Intra-financial Liabilities to banks Interconnectedness system liabilities Liabilities to insurers and Intra-financial other financial institutions system assets in Germany Debt securities Receivables from banks outstanding Receivables from insurers and other financial institutions in Germany Debt securities outstanding Sources: BaFin and the Bundesbank
4 Data set The institutions data are consolidated data at group level taken primarily from the banking supervisory reporting systems at the 31 December reporting date of the preceding year (where available). All institutions in Germany are included in the analysis. If values are not available for particular indicators as a result of the accounting policies adopted, substitute indicators (proxies) are used. Determining the overall score The calculation of the overall score for an institution in the indicator-based scoring model corresponds to the determination of the score in accordance with the EBA guidelines EBA/GL/2014/10. The score of each indicator is calculated as the indicator value for the respective institution divided by the aggregate amount of the respective indicator values for all institutions. The resulting score is then multiplied by 10,000 to express the indicator scores in terms of basis points. The category score for the respective institution is calculated by taking the simple average of the indicator scores in that category. The respective institution s overall score is calculated by taking the simple average of the four category scores. A hierarchy of systemic importance is determined on the basis of the institutions overall scores. Institutions with an overall score that is equal to or higher than the threshold value of 350 bp are automatically classified as O-SIIs in accordance with the EBA rules. All other institutions with an overall score of less than 350 bp down to 4.5 bp may be additionally classified as O-SIIs in Step II. Step II: Scoring model with national discretion In Germany, the quantitative analysis in Step II is based on an expanded indicator-based scoring model (see Table 1), which also reflects the requirements for supervisory assessment from the EBA guidelines. Table 1 shows that some of the mandatory indicators specified in EBA/GL/2014/10 are analysed in greater detail and that optional indicators from Annex 2 of EBA/GL/2014/10 have been added to the quantitative analysis in order to adequately reflect the specificities of the German banking sector. A hierarchy of systemic importance is again determined using the calculated national overall scores. All institutions with an overall score of 100 bp or more are, in addition to the institutions already identified in Step I, classified as O-SIIs. The plausibility of the result is then tested by BaFin and the Bundesbank by means of an expert judgement. This is intended to ensure that the systemic importance of institutions below the 100 bp threshold value in particular is assessed a further time and that the possible designation of additional institutions as O-SIIs is considered. Here, too, the expert judgement focuses on the potential impacts on the financial system arising from a threat to the institution s continued existence or its default.
5 Setting the capital buffer Additional capital buffers may be set for other systemically important institutions by BaFin pursuant to section 10g of the KWG. The maximum buffer of 2.0% permitted by section 10g (1) of the KWG is allocated to the capital buffer classes in 0.5 percentage point increments, yielding four capital buffer classes (0.5%, 1.0%, 1.5% and 2.0%). The identified O-SIIs are allocated to capital buffer classes on the basis of their overall scores and conditional on institutions which are homogeneous in terms of their systemic importance being required to observe the same capital buffer. Homogeneous institutions are grouped together on the basis of a cluster analysis. The capital buffer for the identified O-SIIs will be introduced in three steps from 1 January 2017 onwards so that the buffer will have to be observed in full from 1 January 2019.
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