Collecte des données et contributions au Fonds de Résolution Unique Autorité de Contrôle Prudentiel et de Résolution Direction de la Résolution Novembre 2015 RESTREINT
Sommaire 1. Calendrier du transfert des contributions 2015 2. Calendrier de la collecte des données de calcul des contributions de 2016 3. Reporting des données 2016 4. Calcul des contributions 2016 5. IPC 2015 2016 6. FAQ et Helpdesk 2 RESTREINT
1. Transfers of 2015 contributions 3
1. 2015 Transfer processes Timeline 16 Oct Send template (T1) - NRA’s Official Contact 16 Nov information General communication and sending templates (T2, T3 & T4) Jan Send debit notes 2015 2016 SRB Feb Oct Jan NRAs Nov Dec Jan Complete template (T3) - Payment 28 Oct Amounts Complete template (T1) Tracker - NRA’s Official Contact information 31 Jan Complete money transfer to 31 Dec SRB + complete template Complete template (T4) - IPCs Tracker + IPC & SRB action (T2) - Payment Collateral contracts Amounts : Logic, NRAs action Methodology and Rules applied for All dates are deadlines or due dates calculation 4
2. 2016 Data collection 5
2. 2016 Data collection process Timeline 15 Nov - 30 Nov Test Phase & Clarifications requests on scope of institutions 2016 2015 SRB Nov Dec Feb Mar Jan NRAs 1 Feb 24:00 15 March 12:00 Deadline for Deadline for the institutions to NRAs to sent the 15 Nov -30 Nov provide data final version of the By 3 Feb 25 Feb Test Phase data Sent the initial Sent the interim data as on 1/02 data as on 23/02 24:00 24:00 SRB action 15 February NRAs action Deadline for the Optional action NRAs to sent the EBA aggregate Mandatory action intrabank loans and All dates are deadlines or due dates deposits 6
Checks Principles - According to the DR, the data provided by 1/02/2016 (Monday) should be used for calculation of 2016 individual contributions - In case of missing data the SRB/NRA has an obligation to "use estimates or its own assumptions " – Art. 17 (1); in case of risk indicators the NRA/SRB " may assign the institution concerned to the highest risk adjusting multiplier " - Art. 17(2) - In case of restatements or revisions provided after 1/02/2016, the resolution authority shall adjust the annual contribution for the following contribution period. - Delegated Regulation does not stipulate any particular rules or timeframe for checks - There is a general "good administrative behaviour principle" that in case of "obvious clerical mistakes" an institution should have a possibility of correction - In order to ensure level playing field such corrections must respect strict rules 7
Checks Rules applicable to correction of "Obvious clerical mistakes" 1. The NRA should take the initiative of contacting the institution in writing exclusively. 2. In no case the NRA can correct them on behalf of the institution without its prior written consent. 3. Requests sent to an institution must be very precise: they must be purely factual (e.g. request specific missing data by referring to the data request, request confirmation about the correction of a clerical error in wording or calculation). 4. The principle of equal treatment demands that if one Institution is asked to correct obvious clerical errors, the same must apply to all institutions in the same situation 5. Institutions should not be given an opportunity to provide extra information that may restate or revise the data. 6. The time limit for response must not exceed in principle 2 working days, since all data were supposed to be provided earlier in the initial tender and the correction of errors requires only confirmation of an obvious mistake. 7. The request should remind the Institution that the data submitted may not be revised or restated. 8. Each NRA will have to send to the SRB the -initial, -interim and -final versions of data 8
CHECKS CASE 1 – MISSING DATA necessary for calculation spotted during checks 1/02 15/03 (*) NRA contacts the For Y Provided Institution and requests to 2016 Y within the send correct data within N timeframe? max. 48 hours Is this an " Obvious clerical Lump Sum mistake "? (*) NRA proposes to the SRB estimated value BAC N For 2016 NRA proposes the SRB the Risk estimated the value or Indicator assigns to Max Risk (*) subject to decision on the delivery of aggregate value of Interbank Loans and Deposits to the EBA 9
CHECKS – Case 2 – DATA PROVIDED (incl. zero figure) BUT potential error spotted during checks 1/02 15/03 (*) New Y Value for NRA contacts immediately 2016 the Institution and Provided requests to send new within the Y value within max. 48 timeframe? hours Old N value for Is this an 2016 "Obvious clerical mistake "? (*) New NRA informs the Y value for Institution of the Provided 2017 N possibility of revision of within the restatement until timeframe? 31/01/2017 NO N action (*) subject to decision on the delivery of aggregate value of Interbank Loans and Deposits to the EBA 10
CHECKS – Case 3 – DATA REVISED/RESTATED by institution after 1/02/2015 1/02/2015 31/01/2017 In that case, the revised or restated data are recorded and will be used for adjustment of 2017 contribution 11
Audit certificates/agreed upon procedure The SRB does not have a legal right to impose audit • certificates nor agreed upon procedure arrangements which bear costs for institutions Each NRA may decide to apply additional • certificates/arrangements during the data collection process 12
3. 2016 Data reporting 13
Information flow between the SRB and the ECB According to the Art. 19(3) of Delegated Regulation 2015/63, the competent authorities shall provide the resolution authorities any information enabling the resolution authorities to calculate the annual contributions ECB holds and maintains a list of : • all the credit institutions (at legal entity level) EU consolidation groups (within SSM perimeter) all the IPS (collected during a one-off special data collection in Sep2015) The SSM does not have information on investment firms . • There are differences between the scope of data required by the SRB and the scope of • supervisory reporting data available in the SSM Information available at the SSM about credit institutions is also available for central • bodies ECB/SSM informing the SRB about the setup of a central coordination hub at the Crisis • Management Division 14
- - Total Liabilities Own funds Covered Deposits Covered deposits (Art 4(2),16, 20(4) of the DR 2015/63) Basic Annual Contribution Covered deposits Annual Target Covered deposits as defined in DGSD at the reference date (31 • December 2014) and on 31 December 2015 should be provided by Frequency institutions at individual level • The DGS Directive - (EU) 2014/49- was not transposed in all the Average 2015 Member States yet. The DGSD continues to be transposed, so in 2015 more MSs will be • able to report Covered Deposits Sep'15 Dec'15 Jul'15 Frequency, the regulation 2015/63 requires a yearly average of • quarterly amounts, however since the last quarter of 2015 could not yet be available, we could work with the average of the current data available 15
4. 2016 Calculation of contributions 16
Calculation of contributions Data from credit institutions and investment firms (SRB templates or alternatives) Aggregation at country-level by NRAs Aggregation of 19 NRAs input in 1 SRB file Calculation of contributions 17
Calculation of contributions 18 43
5. 2015 and 2016 IPCs 19
Indicative timetable 20
Contemplated process for the delivery of collateral NRAs notifie institutions SRB decides on IPC (%, (annual amount of the contribution, max % for collateral) IPCs) Institutions inform NRAs NRAs issue a final about their decisions on notification to IPCs institutions Matching between the Institutions transfer the amount of collateral cash to a bank account collected and the amount opened in the name of expected by the NCB that the SRB holds SRB account The SRB decides to Dunning process invest or not to invest the cash received as performed by NRAs collateral 21
Contemplated process for the payment of interest Negative interest rate Positive interest rate 22
How to invest the cash received: Term deposits in period of positive interest Term deposits in period of negative interest rates rates 23
General considerations Only cash is accepted as collateral for 2015 • Cash collected by NRAs will be transferred to SRB in January 2016, • under a contract between the SRB and the NRAs concerned. The SRB is still to decide whether it will allow or not securities as • collateral in the coming years o It may be challenging for the very first years. In any case, we need to know the prerequisites • o To be ready on time. o 18 months may be needed depending on the approach chosen. 24
6. FAQ and Helpdesk (incl. promotional loans) 25
Recommend
More recommend
