Financial Regulatory Observer
September 2017

A German lender tried and failed to remove itself from the clutches of ECB supervision – what does this mean for the wider banking sector?

In May 2017 a small German state-owned bank lost its fight to escape the clutches of ECB supervision in the first judgement handed down by European General Court relating to Single Supervisory Mechanism (SSM).

When it was introduced in November 2014, the SSM created an institutionalized process of supervising credit institutions and became one of three pillars of European Banking Union along with the Single Resolution Mechanism (SRM) and the European Deposit Guarantee Scheme (DGS). The SSM also established the European Central Bank (ECB) as the lead supervisory body for Eurozone banks holding more than €30 billion in assets. Landeskreditbank Baden- Württemberg, which has assets of €70 billion, argued that it should be regulated instead by its national competent authority (NCA)—in this case German watchdog Bafin and the Bundesbank– rather than the ECB on the grounds that its debt is guaranteed by the state of Baden- Württemberg, and as such it posed no systemic threat. L-Bank preferred to be supervised by its national regulator because of the lower cost of compliance.

The General Court rejected the L-Banks’s claim in every aspect. It stated that an exemption from the ECB’s supervision can only be made upon proof that the NCAs’ supervision is better able to attain the supervisory objectives. Hence, L-Bank`s plea that the German NCAs’ supervision was sufficient to attain these objectives couldn’t justify its claim. In short, the judge ruled that the ECB has free reign when it comes to which banks it wants to supervise and delegates to NCAs at its own discretion.

_{€30 billion}

Banks with more than €30 billion in assets fall under ECB Supervision

 

FRO: Henning, some observers have been disappointed by the L-Bank judgment, criticizing its "pro-centralization stance" and the fact that it does not address "the substantive questions at hand." Is this convincing?

Henning Berger (HB): In my view, these observers don’t take into account the circumstances of the case. The L-Bank judgment dealt with a rather narrow legal question and seems to have been led more out of principle than to clarify many of the open questions regarding the SSM. One of these questions concerns the competent courts when the ECB and the NCAs act "in concert". Regarding the latter, there are currently a number of pending cases before the General Court concerning the European Banking Levy, which may give a better understanding of the court’s review of administrative decisions in the European Banking Union.

FRO: So is there anything we can infer from the L-Bank judgment?

HB: The court has confirmed that there is no easy escape from the supervision of the ECB: The ECB has a margin of discretion concerning the question of whether an exemption from its supervision should be made due to its inappropriateness. Hence, the judgment confirms what was to be expected: Significant credit institutions will remain under the direct supervision of the ECB and cannot expect to be easily released into the supervision of the NCAs.

SSM created an institutionalized process of supervising credit institutions

 

FRO: Taking into account the leading position of the ECB in the SSM, what is the remaining role of the NCAs? And how can an institution determine the competent authority?

HB: In general, supervision is now under the umbrella of the ECB, but the NCAs still play an important role in the process. Both act in close cooperation. Firstly, in order to determine the competent authority, we must differentiate between CRR-credit institutions categorized as significant and those that are not. The supervision of significant institutions is carried out directly by the ECB, whereas the supervision of non-significant institutions lies in the hands of the NCAs.

Regardless of the size and significance of an institution, the ECB has some exclusive competences, such as the granting or withdrawal of banking authorizations. But this exclusive competence does not mean that NCAs are excluded from the decision. For example, in case of the authorization of an institution, requests must be addressed to the acting NCAs. The NCAs review the criteria and prepare reasoned proposals for the ECB, which then reviews and adopts where appropriate. In a nutshell, the SSM is a complex and interwoven system of shared and sole competencies. The ECB and NCAs are acting in close cooperation, but in most cases the ECB has the last word.

FRO: In case a decision is made by the ECB but prepared by the NCA, for example the withdrawal of an authorization, related what are the legal steps an institution can undertake to defend itself?

HB: All ECB decisions can be reviewed on an administrative level and an institution can seek judicial protection irrespectively. The competent court depends on the measure in dispute. National administrative courts have exclusive jurisdiction in matters of legal protection against measures taken by a national authority. The actions of a Union authority can only be reviewed by the Court of Justice of the European Union (ECJ).

As some decisions by the SSM are composed of actions by both the NCAs and the ECB, it may be necessary to take legal action before national courts and the ECJ in parallel. In cases where the allocation of a measure is not clear, it may be necessary to seek legal protection before both courts simply as a precaution. The pending cases concerning the European Banking Levy demonstrate how difficult it is even for the authorities themselves to determine who is responsible for a certain measure.

SSM is a complex and interwoven system of shared and sole competencies

 

FRO: The NCAs and ECB apply both European Law, for example the SSM Regulation, and national law. Doesn’t this lead to uncertainties when there are different rules?

HB: There can be uncertainties, but that’s not always the case. Basically, the new European norms apply in addition to the existing national supervisory law, such as the French code monétaire et financier or the German KWG. Together, they establish the supervisory requirements that an institution has to fulfill. Conflicts can result from the fact that these requirements are applied by both the ECB and the NCAs, and the authorities may deviate in their practices. In this regard, a revolutionary feature of the SSM is that the ECB must apply national law based on European law. As the applicable national laws may differ, the ECB will strive to harmonize its practice as far as possible.

FRO: Are there examples of this practice?

HB: Of course. For example, in the ECB’s application of the fit-and-proper-rule, the compulsory assessment procedure concerning the appointment of new management does not apply across the entire EU. However, the ECB has developed a formal procedure that it applies to the appointment process within all member states. Consequently, in member states that don’t prescribe the formal approval of members of the management body, the ECB has factually introduced such a procedure of approval. This has a significant impact, as fit-and-proper proceedings are of great practical relevance to the institutions.

FRO: All in all, what are the main challenges banks have to face under the SSM?

HB: As the practice of the SSM and the courts develops over time, a clearer allocation of procedural acts and competencies will emerge, making it no longer necessary to seek legal parallel protection. The same is true for other legal uncertainties as the standards of fit and proper the ECB can apply.

Besides that, language barriers between the ECB on the one hand and NCAs and banks on the other hand can be challenging. Even though institutions can choose the language they use for their communication with the ECB, the latter usually aims at establishing English as the language of communication. The communication between the ECB and NCAs has been agreed to be in English. Still, the internal working language in most NCAs and banks is not English. This does not only entail a substantial translation workload, but also a lack of transparency and comprehensibility, especially when an institution cannot easily clarify and defend its practice to the ECB. At first sight, this may seem surprising, but in practice it can be quite an issue.

Meanwhile differing legal cultures among the member states can lead to a diverging understanding of the applicable supervisory criteria and the extent of judicial review of decisions. Although joint supervisory teams (JSTs) have been created to discuss these differences, the ECB’s practical approach can differ from that of the NCAs. As a result, banks may expect a different interpretation of the prudential regulations based on national practice than the ECB will take. All in all, the SSM is a perfect example of the special challenges and difficulties of European cooperation and integration in general. Overcoming these is an ongoing process.

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Regulators are trying to bring consistency in calculating risk-weighted assets, casting further doubt on the use of internal models by financial institutions.

The Capital Requirements Regulation (CRR) requires credit institutions to hold their own funds in sufficient quantity and quality to address the various risks they are exposed to. In particular, they need to hold own funds in an adequate amount to be in a position to absorb potential losses arising from credit risk.

The amount of own funds a credit institution must hold with respect to credit exposures is not a statistical value but a risk-adjusted amount based on certain regulatory calculation methods. Since January 1, 2007, when the Basel II framework was fully implemented into European law, the EU framework allows credit institutions to use two different approaches when calculating their risk-weighted credit exposure, thereby determining the minimum amount of regulatory capital they must hold.

Whereas the standardized approach provides a calculation method where the risk parameters are predetermined by the relevant supervisory authority, the internal ratings-based approach (IRB approach)—established as part of Basel II—allows a credit institution to determine various risk parameters on the basis of internal historical data. Accordingly, Basel II (and its implementation into European law) enabled credit institutions to reduce the risk weights of their credit exposures compared to the standardized approach, potentially resulting in lower regulatory capital requirements.

Credit institutions need to hold adequate own funds to adsorb potencial losses from credit risk

 

The Basel Committee's proposal on reducing the variation in credit risk-weighted assets

However, the way in which credit institutions may use these calculation methods are under scrutiny. In March 2016, the Basel Committee on Banking Supervision issued a consultative document on reducing the variation in credit risk-weighted assets (RWAs) and placing constraints on the use of internal model approaches. The Committee proposed changes to the IRB approach to reduce the complexity of the regulatory framework, and improve the comparability by addressing the variability in the capital requirements for credit risk. In this regard, the proposals of the Basel Committee on Banking Supervision included the following:

• Removal of the option to use IRB Approaches for certain exposures
• Adoption of exposure-level, model-parameter floors to ensure a minimum level of conservatism for portfolios in relation to which IRB Approach remains available and
• Reduction of the variability in RWAs for portfolios in relation to which the IRB approach remains available

The proposals sought to limit a credit institution's ability to benefit from the use of internal models by introducing input floors that would constrain risk parameters for specific portfolios and by setting a minimum output floor on the basis of standardized models. The output floor was designed to mitigate model risk and measurement error stemming from internally modeled approaches that would place a limit on the benefit a credit institution derives from using its internal models for estimating regulatory capital. The Basel IV reform package also suggested that internal models may no longer be used for certain exposures, such as large corporates and specialized lending exposures. In effect, the transposition of Basel IV would significantly increase the amount of RWAs, resulting in higher own funds requirements.

However, this proposal was blocked by the chairmen of all national supervisory authorities and central banks as the highest body of the Basel Committee, who voted against it on January 8, 2017. A European coalition led by the German Minister of Finance, Wolfgang Schäuble, was able to block the proposal against the will of the United States, as the decision-making process requires a consensus of the Committee members.

As the European banking sector widely uses and depends on the IRB approach, European supervisors were aware that the new proposal would have had adverse effects on the European market, while having nearly no impact on the US. This is because banks in the US have mostly recovered from the financial crisis of 2008, having robust balance sheets and primarily already use the standardized approach. Furthermore, the US securitization market is booming, allowing US banks to free up regulatory capital by selling securitized loans in the capital markets. Meanwhile, large European banks still struggle with their legacy portfolios, thus relying on the IRB approach to comply with regulatory capital requirements.

The current discussion on the use of IRB Approaches is not new. Instead, similar discussions and controversies between the US and the EU arose in the context of Basel II—then as now issues to be dealt with were the possibility of abusing internal models by tweaking the systems to lower the capital requirements, and the lack of comparability between banks and especially between credit institutions located in the US and Europe, respectively. In the US, the use of internal models is already restricted by the Dodd-Frank Act, resulting in the eligibility of internal models for only the 19 biggest US banks.

In the ongoing negotiations, the EU is therefore put in a situation where it is confronted with reasonable criticism of internal models. In addition, it has to defend regulatory advantages European banks currently benefit from.

34%

The average risk weight on certain asset classes may be raised from 26% to 34% following the introduction of TRIM

Institutions should, however, in all circumstances explore the options at hand as change, in whatever form it may eventually come, is on its way

 

Assessment of the European Central Bank

As a response to the issues described above, the European Central Bank (ECB) has released a new explanatory statement on its Targeted Review of Internal Models (TRIM) on February 15, 2017. TRIM was launched in late 2015 and is expected to be finalized in 2019. The project is expected to assess the overall reliability and comparability of the internal models currently used and whether they comply with regulatory requirements. It also aims to reduce regulatory arbitrage which allows banks to exploit inconsistencies and create unwarranted variability in their risk models compared with those of rivals. Danièle Nouy, Chair of the Supervisory Board at the ECB, said in an interview in 2015: "We will start with the banks that markedly understate their capital requirement through the use of their models; our aim is to find out whether that is justified or whether the parameters need to be adjusted."

In July 2016, the ECB published a research paper on IRB risk assessment, which depicted that the internal models currently used may not be reliable. The paper compared the actual default rates of recent years with the results of the IRB Approach and the standard model in the German banking sector. It concluded that at the aggregate level, reported probabilities of default and risk weights were significantly lower for portfolios that were assessed in accordance with the IRB approach, compared with those assessed under the standard approach. By contrast, ex-post default and loss rates went in the opposite direction: Actual default rates and loan losses were significantly higher among the IRB portfolios compared with the portfolios assessed in accordance with the standard approach.

The initial reaction by individual banks to the introduction of TRIM by the ECB in 2017 suggests that the average risk weight on certain asset classes (such as mortgage portfolios) may be raised from 26 percent to 34 percent. Other analysts suggest that TRIM could hit CET1 levels by as much as 60 basis points. Accordingly, the impact of TRIM on the balance sheets of European banks should not be underestimated.

While maintaining the possibility of banks using internal models, the ECB wants to ensure that they are being used appropriately. In a statement on February 15, 2017, the ECB explicitly answered the question as to whether internal models will continue to exist after the finalization of Basel IV: "[…] ECB believes that internal models can play a useful role in determining regulatory capital according to the institution's risk exposure, provided that certain conditions are met: risks must be modeled adequately and models must give consistent results."

This approach and the timing of the explanatory statement lead to the conclusion that the ECB's intention is to weaken the arguments brought forth by the critics of internal rating systems and thus establish a solid foundation for future discussions in the Basel Committee.

However, the results of the TRIM exercise remain to be seen. The ECB wants more consistency and adequacy in model outputs and comparability of risk-weighted exposure amounts. This is similar to the approach pursued by the European Banking Authority (EBA) in the draft regulatory technical standards it published in July 2016. The standards look at the specification of the assessment methodology for competent authorities regarding compliance of an institution with the requirements to use the IRB Approach.

Internal models should not be removed, as they are too important for the European banking sector, but some European banks should be braced for higher risk weights, particularly when it comes to on non-performing loan portfolios (NPLs). For example, most of the Italian banks apply zero risk weight for such non-performing loans, which does not reflect the real economic risk and lacks the necessary comparability for investors.

IRB models currently used by many banks may not be reliable

 

Outlook and solutions for credit institutions

The above considerations highlight that it cannot be said with certainty at this stage which models will be used by credit institutions to calculate their risk weights in the future. In particular, the complexity of the issues under discussion, as well as the ECB's ongoing TRIM process, raise questions about whether the review as envisaged will coexist with potential changes to the legislative framework or if such changes will be postponed and/or substituted by TRIM. Some suggest that instead of introducing output floors, increased transparency and disclosure requirements (for instance with regard to the breakdown of asset portfolios or the rationale behind increased capital requirements) would be better suited to improve market discipline and comparability between credit institutions' capital ratios.

The current reform on the capital treatment of securitization exposures as envisaged in the legislative package for a CRR amendment (Draft CRR) and for a Regulation of the European Parliament and of the Council laying down common rules on securitization and creating a framework for simple, transparent and standardized securitization (the STS Regulation) might serve as an indicator for future steps to be expected when calculating credit risk.

Both the review of internal models, as well as potential legislative changes with regard to the calculation of risk-weighted credit exposures, is likely to result in an increase in regulatory capital requirements due to significantly higher RWAs. Credit institutions therefore have to explore options to deal with the risks they are exposed to, thereby lowering their RWAs and, ultimately, the amount of regulatory capital they must hold. Risk-sharing and the transfer of certain risks from the respective credit institution's credit portfolio by means of a synthetic securitization transaction offer a viable solution in this regard, as the CRR provides for a more favorable calculation of risk-weighted exposure amounts and expected loss amounts if a significant portion of the credit institution's credit risk is transferred.

Which option credit institutions ultimately choose heavily depends on their current use of internal models. Institutions should, however, in all circumstances explore the options at hand as change, in whatever form it may eventually come, is on its way.

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New formal cybersecurity standards covering US financial institutions could have ramifications that reach far beyond New York.

US regulators usually issue cybersecurity guidance instead of regulator standards and requirements. That changed on March 1, 2017, when the Superintendent of New York's Department of Financial Services (NYDFS) exceeded federal efforts and put into effect Cybersecurity Requirements for Financial Services Companies (Cybersecurity Regulation).

Following a spate of cyber-attacks and breaches of customer confidentiality, the NYDFS declared that for certain financial institutions operating in New York "regulatory minimum standards are warranted". Although this edict directly applies only to banks, insurance companies and other financial services institutions specifically regulated by the NYDFS, (i.e., with operations subject to the jurisdiction of the NYDFS), financial institutions are finding that the requirements may apply indirectly to foreign headquarters and branches located throughout the world.

Cybersecurity Regulation may apply indirectly to foreign branches of financial institutions

 

Purpose and requirements

The Cybersecurity Regulation is an ambitious regulatory initiative not limited to protecting consumer privacy. Rather, by focusing on all nonpublic information (including business confidential information unrelated to individuals) as well as on network stability, the NYDFS requires that its regulated entities, "ensure the safety and soundness of the institution," while also protecting their customers. The Cybersecurity Regulation was promulgated to address the growing concern of financial industry regulators with the vulnerability of personal, financial and business data processed by NYDFS-supervised organizations and to protect the associated level of security of their information technology systems against systemic harm.

The NYDFS's methodology for entities to achieve the agency's desired result involves a mix of risk management principles and compliance demands. At its core, the Cybersecurity Regulation requires an extensive list of regulated entities to implement and maintain a thorough 14-point cybersecurity policy with requirements that range from asset management to incident response. Covered organizations (and individuals) are required not only to consider "relevant risks" to their business, but also to "keep pace with technological advances."

The minimum standards imposed on organizations and individuals under the Cybersecurity Regulation address several areas, including:

• Requiring certain physical, administrative and technical controls to ensure that an organization's cybersecurity program addresses cybersecurity risks, and protects nonpublic data and the information systems, including written cybersecurity policies and procedures, encryption, multi-factor authentication, penetration testing and risk assessment
• Implementing a corporate governance framework that involves participation and oversight at all levels —from vendors to the board of directors —and requires reporting to executive management on evolving cybersecurity risks to facilitate necessary revisions to the cybersecurity program
• Submitting an annual certification, prepared by executive management, to the Superintendent of the NYDFS confirming compliance with the Cybersecurity Regulation, and documenting necessary material improvements to the cybersecurity program

Developing and implementing a written incident response and remediation plan addressing internal incident response processes, goals of the response plan, delineation of clear roles and responsibilities for incident response decision-making authority, external and internal communications, requirements for remediating cybersecurity weaknesses, cybersecurity event and incident response documentation and reporting, and evaluation and revision of the plan. Some organizations may qualify for relief from certain or all compliance obligations under the Cybersecurity Regulation if they fall under one or more of nine exemptions. These exemptions may be available based on the size of an organization, reliance on the cybersecurity program of another related entity, access or control over nonpublic information or information systems, or designation as a special insurance or reinsurance entity. Absent an exemption, organizations that fail to comply with the Cybersecurity Regulation may be subject to penalties and enforcement actions by the Superintendent of the NYDFS under existing law.

14-point

Cybersecurity Regulation calls for a 14-point cybersecurity policy for all regulated entities

 

Global reach

Importantly, the Cybersecurity Regulation has an extraterritorial reach that extends well beyond the regulated entity itself. Typically, many large enterprises gain business efficiencies and closer coordination between their subsidiaries and affiliates by deploying a unified information technology platform with centrally managed security. Thus, if a segment of the enterprise, however small, falls under the jurisdiction of the NYDFS, the enterprise's broader program may effectively fall under its watchful eye and will have to meet the Cybersecurity Regulation's requirements to the full extent it is relied upon by the enterprise's NYDFS-regulated entity. In these instances, all the relevant documentation and information about the larger program must be made available to the NYDFS upon its request. Similarly, when regulated entities use vendors, NYDFS requirements exist to ensure the appropriate level of security for the information and systems that are accessible to, or held by, third-party service providers.

For foreign organizations with branches, employees, subsidiaries or affiliates operating in New York State, the reach of the Cybersecurity Regulation warrants full attention and consideration. If a foreign organization determines that the Cybersecurity Regulation applies to its affiliates, third-party service providers or employees operating in New York, then the organization could be beholden to the NYDFS for cybersecurity program inquiries. This could mean, for example, that a foreign-based organization's overall cybersecurity program documents and practices may be open for review and inspection by the Superintendent of the NYDFS based on its New York operations thousands of miles away from its core and broader operations and activities, including across multiple jurisdictions. It could also mean that foreign third-party vendors who provide cybersecurity program services to the organization or its affiliates may be subject to certain obligations under the Cybersecurity Regulation.

This potential reach of the Cybersecurity Regulation raises legitimate jurisdictional concerns about a local regulator's ability to obtain insight into the network security of a global enterprise, regardless of where the company is headquartered. In addition, foreign companies could begin to see compliance costs rise due to conflicting cybersecurity standards set forth under other laws, such as the General Data Protection Regulation, or if other states in the US, or other countries, begin to promulgate similar regulations that are not harmonized with New York's Cybersecurity Regulation. Thus, companies should be aware that aspects of their enterprise-wide cybersecurity programs and controls could come under the ambit of the NYDFS and prepare accordingly. For enterprises with significant worldwide operations, failing to appreciate the potential reach of the NYDFS under the Cybersecurity Regulation could present significant issues.

Cybersecurity Regulation has an extraterritorial reach that extends well beyond the regulated entity itself

 

72-hour incident reporting

The Cybersecurity Regulation also requires covered entities to notify the superintendent within 72 hours of its determination that an act or attempt, whether or not successful, was made to gain unauthorized access to, disrupt, or misuse, an information system or the information stored on it, to the extent that (a) notice is required to be provided to any government body, self-regulatory agency or any other supervisory body; or (b) the event has a reasonable likelihood of materially harming any material part of the entity's normal operations. To determine whether an unsuccessful act or attempt is reportable, organizations will want to consider whether defending against it was routine in nature or required taking measures "well beyond" those ordinarily used.

C-suite-level involvement

The significance of the global reach and tight 72-hour incident reporting timetable of the Cybersecurity Regulation is amplified by the requirements placed on officers and directors of a covered foreign organization to oversee and manage the cybersecurity program applicable to its New York operations, and to document their review, understanding and approval of the program. Should the NYDFS request a review and access to an organization's cybersecurity program, the role and involvement of the organization's officers and directors in implementing the program will come under scrutiny. Therefore, in addition to appreciating the extraterritorial reach of the Cybersecurity Regulation outside of New York, senior officers (and boards of directors) should focus on the following obligations: ESMA anticipates that legal questions will arise as the technology develops and its applications become more visible. It believes that it is too early to gain a complete understanding of the changes that the technology may introduce and that any regulatory action would be premature.

• Review and approve the organization's written cybersecurity policy and ensure that it addresses the specifically enumerated topics under the Cybersecurity Regulation. The cybersecurity program should consider not just personally identifiable information, but all nonpublic business-related data as well as the resilience of key systems
• Confirm that the annual report from the chief information security officer (CISO) is generated and provided to the Board. The Cybersecurity Regulation specifically requires the CISO to provide a written report to the directors on the cybersecurity program and any material risks
• Ensure that the organization's risk assessments, third-party service provider policies, and incident response and remediation plans are tracked and documented. This documentation is necessary for officers and directors to annually certify that they have reviewed the documentation and that the organization's cybersecurity program is compliant with the Cybersecurity Regulation. Should the superintendent request review of the cybersecurity program, then the documentation provides proof of compliance
• Become familiar with the organization's existing documentation procedures and adjust as necessary. Executive management should seek guidance on how to limit documentation only to what is necessary to show compliance, taking into account any applicable legal privileges

Enforcement actions againts US-based entities may implicate foreign interests on a potentially much larger scale than many firms may reasonably anticipate

 

Vigorous compliance

The Cybersecurity Regulation is intended to protect individual and business-confidential information related to financial institutions, and the integrity and availability of such data, as well as an organization's networks and applications. In promulgating the Cybersecurity Regulation, the NYDFS is attempting to protect a critical infrastructure important to New York—the banking and finance industry. As a result, the NYDFS is expected to vigorously pursue and monitor compliance with the Cybersecurity Regulation, which could result in enforcement actions against US-based entities that may implicate foreign interests on a potentially much larger scale than many firms may reasonably anticipate. Based on recent history, the New York operations of non-US banks have been a frequent target of the NYDFS (with respect to other issues, to include anti-money laundering and sanctions compliance programs and enforcement); it is reasonable to assume these institutions will continue to be within the NYDFS's sights. Given the extraterritorial reach of the Cybersecurity Regulation and the NYDFS's willingness to exercise its reach in other contexts, organizations near and far should take heed, and be prepared to act quickly.

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