Stellungnahme DK on EBA Consultation Paper “On retail de-posits subject to higher outflows for the purposes of liquidity reporting under Regulation (EU) No 575/2013 (Capital Requirements Regulation – CRR)” (EBA/CP/2013/34)

1. Oktober 2013

Die Deutsche Kreditwirtschaft hat Stellung genommen zur Konsultation der EBA zu geplanten Guidelines zu höheren Abflussraten bei bestimmten Retail-Einlagen.

Aus der Stellungnahme:
First, we would like to point out that we welcome the application of the 5% weight for stable retail ac-count deposits. However, we propose waiving the need for a fundamental, comprehensive review of the seven risk categories for deposits which meet the precondition under Art. 421(1) CRR and to only request such a review if and when banks possess obvious evidence that – in the event of a market-wide and bank-specific stress scenario - the expected outflow rate for the respective deposit will differ from the 5% set out under the Discussion Paper’s current proposals.
Along with the aforementioned seven criteria, under Indent 13, the EBA seeks to oblige banks to review even further characteristics as to whether they indicate or might be used as measure for higher outflow rates in the field of retail deposits. To this end, Indent 13.1 to 13.7 lists numerous requirements which would incur considerable implementation costs. This relates to the implementation of the new data requirements during the identification of the risk factors at the level of individual transactions as well as the collation of a data history for the respective categories needed in order to calculate an estimated outflow rate. Frequently such data are non-existent on the level of the individual transaction or, moreover, on an aggregated customer level. […]


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