Prof. Dr. Stefan Zeranski and Prof. Dr. Svend Reuse prepared a statement from the ZWIRN on the consultation of the German Federal Financial Supervisory Authority (BaFin) dated 05.09.2017 on the "Supervisory assessment of bank-internal risk-bearing capacity concepts

  • 8/27/18 3:46 PM
  • Carsten Kühne

Prof. Dr. Stefan Zeranski and Prof. Dr. Svend Reuse prepared a statement from the ZWIRN on the consultation of the German Federal Financial Supervisory Authority (BaFin) of 5.09.2017 on the "Supervisory Assessment of Bank-Internal Risk-bearing Capacity Concepts and Reorientation of the Supervisory Guidance on Risk-bearing Capacity". BaFin updated its previous opinion on risk-bearing capacity (RBC) in the context of the EU Banking Union. She introduced the RTF perspectives from the economic and normative perspective. The new path of BaFin is to be welcomed in principle. However, from the point of view of the ZWIRN researchers, there is still need for action in the field of sustainability, for example: The new risk-bearing capacity concepts can be geared even more consistently to the sustainability of business models, which from a business point of view includes sustainability indicators and taxonomies In addition, for example, operationalize the social and reputational legitimacy as well as the trust as a sustainable business base for the operation of banking transactions and include it in the risk-bearing capacity. Another point is the stronger networking of success and liquidity risks in the risk-bearing capacity, in particular as a result of immediate payments to liquidity crises, liquidation discrepancies in the liquidity buffer (eg in the high quality liquid assets of the liquidity coverage ratio) and high liquidity costs Liquidity risk costs, which, in addition to the liquidity risk-bearing capacity, also burdens the equity risk-bearing capacity through liquidity-effective performance risks. The new Minimum Requirements for Risk Management (MaRisk) of 27.10.2017 require in particular Part BTR 3.1 (5) on liquidity risk a causal internal offsetting of the respective liquidity costs, benefits and risks in terms of own funds risk-bearing capacity and periodic success. On the basis of the comments received so far, BaFin conducts a second round of consultations before publishing the final version of the guideline on the supervisory assessment of bank-internal risk-bearing capacity concepts.

 

to top
Print