In your plans for 2017, you are prioritising the preparation of an internal benchmarking exercise of all resolution plans in order to enhance coherence.
You also attach importance to the harmonisation of national laws to help improve resolution readiness, and you say that there is significant scope for such harmonisation.
Would you agree that there is a danger when following this kind of approach, namely that it could develop along one size fits all lines? If yes, what is being done to contain this potential problem?
Specifically, when it comes to medium sized banks from the small and not so small economies of the south, are there not particular features of a structural nature in those economies which require a different treatment from those of the north? Applying resolution mechanisms that have been harmonised to such banks reflecting methods used elsewhere could further reduce their financial flexibility in their own relatively small environments, making them uncompetitive with the bigger northern banks.
Indeed is there not the possibility overall that harmonised resolution procedures would serve to further promote the oligopolisation of banking systems on a European scale? Would we want this to happen?
Answer
When we talk about benchmark we are talking probably by far more in the detail and I give you an example..we have some banks where the teams and the teams are our own staff and the staff of national authorities have identified 20 plus critical functions and then you have a bank which is by far larger and you identify three or four critical functions…so when I say benchmarking we need to make sure that we use the same yard stick in defining what’s critical in each and every of our teams..when defining how serious we whant to look at this and that..that we have the same yard stick. We are perfectly aware that you have…I would not follow your line of thought in the distinction between South and North but you’ve got different buisness models…you might have institutions which are entirely retail funded in the sense that they have equity…they have deposits and then they land to small and medium sized companies…those exist in Europe…they exist in the North and they exist in the South and they are definetly a different animal from an investment bank type institution and you need to look at this differently and you probably came to different resolution considerations..but benchmarking for us is needed also because we are following a bit the line of having clustered banks in different countries so there we have to make sure that we are not giving one country a different threatment then another country and when we talk about looking into national items I can use one example we found in one case that due to the detailed national insolvency law, it makes perfect sens to request the banks there to form a holding company on top of the operating company. This might not be the case in other countries. I want to put it the other way round. We start with a resolution plan that it has to be enacted under national law..so we really need to have a clear handle on the national law and we need to dig deeper into this. This was the case. We are very mindful that we need to treat all the banks, not just one size fits all, but also consistent within the banking union.
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