Im Europaparlament hat die Debatte Fahrt aufgenommen, wie viel die verschiedenen Banken in den zukünftigen Europäischen Abwicklungsfonds einzahlen müssen. Zusammen mit KollegInnen der Christdemokraten, Sozialdemokraten, Liberalen und Grünen habe ich einen Brief an Binnenmarktkommissar Barnier geschickt. Darin fordern wir den Kommissar auf, sich dafür einzusetzen, dass riskante Großbanken ihren angemessenen Beitrag leisten. Das bedeutet Großbanken, die riskante Geschäfte eingehen, sollen auch wirklich einen angemessenen Beitrag in den Europäischen Abwicklungsfonds einzahlen. Außerdem sollen die Geschäftsmodelle von kleineren Banken (z. B. ihr Geschäft mit der KfW) angemessen berücksichtigt werden.
BRRD/SRM Delegated Act – Calculation of Contributions
Dear Commissioner Barnier,
At the ECON committee meeting on 22nd July, members had their first opportunity to discuss with your services a detailed position of the Commission on the BRRD delegated act determining the calculation of contributions to resolution funds, including the Single Fund for the SRM.
While we appreciate the difficult task of reconciling the divergent views expressed by member states in the Expert Group sessions, it emerged in that meeting that members across political groups have serious reservations on key aspects of the latest proposals:
Proportionality
The legal basis for the delegated act clearly states that contributions need to be risk based. This principle needs to be upheld. It is, therefore, indispensable that the risk spread fully reflects the differences in risk profiles of the credit institutions. The risk adjustment has to be calibrated so as to ensure that there is an appropriate distribution of contributions between the institutions according to their riskiness. A spread of 80% to 150% of the BRRD base (a multiple of below two as currently being considered) in the risk adjustment cannot be accepted as adequately reflecting differences in risk profile without strong empirical evidence. In this context, it is worth noting that the current FDIC contribution schedule allows for the riskiest banks to be charged at a much higher multiple (up to 18 times) compared to the least risky banks.
Furthermore, it is essential to recognise that systemic risk and risks pertaining to the sovereign-bank nexus are key risk categories justifying the creation of a single resolution mechanism in the first place. Hence, systemic relevance of a bank ought to play a significant role in determining the level of contributions. A weight of 10% would appear to be far too low, bearing in mind that systemic risk tends to be highly non-linear in key parameters such as size and interconnectedness of a credit institution (which should be taken into account not just at European but also at international level).
In order to promote financial stability and a true single market, it is essential that TBTF banks pay the overwhelming share of contributions. Failure to do so would in effect result in a further disproportionate advantage for such banks in relation to those banks unlikely ever to be put into resolution. In this context we also question whether it is appropriate only to consider the „risk weighted assets/total assets“ factor and suggest also taking into account factors such as the „equity ratio/leverage ratio“ in order to limit the dependence of the calculation on the outputs of internal risk models which the present crisis has demonstrated to be somewhat unreliable.
Overall, the Commission should provide the Parliament with evidence that their proposal does indeed meet the aforementioned objectives and does ensure a fair distribution of contributions.
Development banks
In the light of the need to stimulate the real economy, in particular SMEs, loans made by development banks and merely passed on by intermediate banks (while incurring no credit risk) should not be included in the BRRD base of the “pass through” banks.
Netting of derivative positions
Netting of derivate positions should not be allowed since otherwise, the true risk exposure of the credit institutions in question stands to be significantly and systematically underestimated.
Intragroup liabilities
Intragroup liabilities are an indication of interconnectedness, and as a general rule should not reduce the BRRD base for contributions. However, if the deduction of intragroup liabilities were allowed under strict conditions, this rule would need to be applied in a non-discriminatory way to all similar structures.
Deduction from tax base
In order to ensure a level playing field between the credit institutions contributions to the SRF should be treated equally in all Member States. The European Commission should ensure that there are no loopholes to circumvent the amounts of contributions in participating Member States. Specifically, it is to be ensured that contributions to the SRF are not tax deductible. This is of particular importance since the mechanisms now being put in place might not suffice to shield the taxpayer entirely from the fall-out of any mayor banking crisis in the future.
We wish, in closing, to underline the commitment of the vast majority of ECON members to achieve, as rapidly as possible, the highest level of quality in this legislation, one of the most important delegated acts you will adopt in relation to BRRD and SRM. At the same time we have to stress that the delegated act has to realise fully the principles set by the co-legislators in the BRRD rather than just corresponding to a compromise between member states. As ECON members, the former principles will continue to be our yardstick and we intend to use our powers if necessary.
We therefore trust you will encourage your services to make every attempt to take account of the views of the Parliament’s negotiating teams on this crucial legislation over the coming months.
Yours sincerely,
Burkhard Balz
Udo Bullmann
Sven Giegold
Gunnar Hökmark
Danuta Hübner
Philippe Lamberts
Olle Ludvigsson
Siegfried Muresan
Ludek Niedermayer
Dariusz Rosati
Andreas Schwab
Peter Simon
Jakob von Weizsäcker
Pablo Bidegain Zalba