Single Resolution Board Dialogue

BPFI attended the recent Single Resolution Board’s Industry Dialogue meeting in Brussels which brought together representatives from EU-level and national banking federations from Banking Union countries, representatives from National Resolution Authorities, the European Commission, European Parliament and the European Central Bank.

Institutions should take note that the Commission has adopted a Delegated Regulation on Administrative Contributions to the SRB in September 2018. From 2018 on, in Q1 of each year, the SRB will collect the annual contributions from all institutions that fall in the scope of the SRM Regulation in the 19 participating Member States. The first invoices are expected to be issued in March with a payment deadline of 35 days thereafter. Institutions will be informed in January if they are in scope of the administrative contributions.

EU Regulation on “STS” Securitisation

In October the European Parliament voted to adopt the EU regulation creating a European framework for “simple, transparent and standardised” (STS) securitisation and amending the Capital Requirements Resolution (CRR). The Regulations will enter into force 20 days after publication in the Official Journal of the European Union, which is likely to be in early 2018, and will apply from 1 January 2019. It will then be directly applicable law across the EU, and will not need transposition into national law by EU Member States. The full details of the new regime will only be known once the various Regulatory Technical Standards (RTS) have been finalised.

The passage of the Regulations through the EU legislative procedures has been lengthy. BPFI has been involved at every stage of the process.

Stakeholder Engagement

Members of the BPFI team recently held a very useful series of meetings with key stakeholders in Brussels.  The BPFI CEO, Director of Banking & Payments, Director of Public Affairs and Head of EU Affairs were joined by the FIBI Chairman to focus principally on Brexit-related business but also cover other matters on the banking agenda.  Engagement included instructive meetings with members of the Barnier Task Force members of the Irish Permanent Representative Office with Dr Kay Swinburne, Conservative MEP for Wales and Vice Chair of the EP’s Economic and Monetary Affairs Committee; as well as with Brian Hayes MEP and member of the EP’s Economic and Monetary Affairs Committee together with advisers to a number of the other Fine Gael MEPs.

Stakeholders from various Government Departments, State agencies, the Central Bank as well as from business and consumer groups were among those in attendance at a number of our recent events, including:

  • FIBI Annual Lunch where Matt King, Managing Director and Global Head of Credit Products Strategy at Citi, posited that the wave of credit driving markets has peaked
  • BPFI National Conference where practitioners and policy makers from home and abroad addressed the theme of ‘transforming banking for customers’
  • Our Changing Regulatory and Supervisory Environment conference which explored the continuing transformation of the supervisory and regulatory framework for financial institutions in Europe. Speakers included ECB Deputy Director General, Giuseppe Siani and Dominique Laboureix, Board Member, Single Resolution Board.

Risk Reduction Package Developments

The negotiations on the European Commission’s Risk Reduction Package are continuing in Brussels. A Council Working Group meeting took place on 28 November where no compromise was reached which means the negotiations will continue under the Bulgarian Presidency from January onwards. BPFI understand that there are still a large amount of outstanding issues to be determined, including key issues such as the IPU, Moratoria and MREL.. The latest Council Papers discussed the possibility of two IPUs and included a section on a transitional arrangement of four years, which are both positive developments.  Minimum Requirements for Eligible Liabilities (MREL) and MREL guidance, improved wording for Bank Recovery and Resolution Directive (BRRD) Article 55 (contractual recognition of bail-in) were also features of the recent discussions at Council.

The Basel Committee is expected to reach an agreement on the Basel 3 package of regulatory reforms at its meeting on December 7, some of these policies are interlinked with the risk reduction package and we are keenly awaiting developments internationally.

SME Regulations

The Central Bank of Ireland (CBI) confirmed in writing its intention to amend the SME Regulations 2015 to rectify the difficulties arising from the definition of enterprises. The CBI confirmed a process of targeted consultation has now ended and that it intends to publish Amendment Regulations before the end of the year, subject to completing the necessary governance and consultation processes. BPFI has engaged with the CBI over an extensive period on this matter and awaits publication of the Amendment Regulations in the coming weeks.

Banking Union

The Commission has published its Communication on Banking Union and accompanying report on the functioning of the Single Supervisory Mechanism (SSM), stating that the SSM is working well and that no revision of the SSM regulation is required at present. Key actions outlined include calls for political agreement on the Risk Reduction Package, a re-start of negotiations on the European Deposit and Insurance Scheme, agreement on a common fiscal backstop to Banking Union, a package of upcoming measures in Spring 2018 to address Non-Performing Loans (NPLs), a forthcoming proposal on the prudential treatment of investment firms and the possible introduction of an enabling framework for sovereign bond-backed securities. The Commission has set out its hopes for finalising Banking Union by the end of its mandate in Autumn 2019, however progress will be dependent on political developments in the Member States over the coming months and the collective political will at EU level. Meanwhile the European Parliament is preparing a non-legislative report reviewing the functioning of Banking Union during 2017, which will be voted in the New Year. While non-legislative, this report can spark debate at EU level on issues of note.

FraudSMART Fraud Awareness Campaign

As a part of Ireland’s inaugural Financial Fraud Awareness Week in October, BPFI launched a new fraud awareness campaign entitled FraudSMART. The campaign involves a full marketing and communications suite aimed at making the public more informed, aware and conscious of financial fraud. The campaign is targeted at a range of different markets, including SMEs, the elderly and youth segments. Advertisements have featured across radio and online channels, including on the Newstalk Network, RTE Radio 1 and Today FM.

FraudSMART featured in over 20 articles throughout the launch week, from national and local newspapers to online forums, and reached a total readership of 1.2m consumers. In addition, BPFI’s Fraud Awareness Manager was interviewed on local radio stations around the country. Online presence was a key feature of the campaign with FraudSMART videos being viewed nearly 200k times. Social media channels reached nearly 400k consumers. More information is available at

EU Commission Work Programme 2018

The European Commission published its 2018 work programme in October. Most notable is the withdrawal of the controversial Bank Structural Reform proposal. Originally presented in 2015, the Commission acknowledges that “no foreseeable agreement” between negotiators is possible, and that other regulatory measures have addressed the rationale for the original proposal. Another interesting element of the work programme is the announcement of a “New Deal for Consumers”, which will see initiatives to enhance judicial enforcement and out-of-court redress of consumer rights, along with proposals to facilitate coordination and action by national consumer authorities.

A number of forthcoming actionable items in relation to key priorities of the Union are outlined in relation to the Digital Single Market, Banking Union, Capital Markets Union and Monetary Union. On the latter, the Commission announced proposals including; the transformation of the European Stability Mechanism into a European Monetary Fund, the creation of a dedicated euro area budget line within the EU budget providing for structural reform assistance, a stabilisation function, a backstop for the Banking Union, a convergence instrument for euro membership and lastly, a forthcoming communication on the creation of a permanent European Minister of Economy and Finance.

Enhanced Mortgage Measures: Transparency and Switching

The Central Bank of Ireland (CBI) published a consultation on ‘Enhanced Mortgage Measures: Transparency and Switching’ in August 2017. BPFI reviewed the proposed amendments to the Consumer Protection Code (CPC) and developed a response to the consultation with the support of members. It is clear from the latest BPFI Housing Market Monitor that consumers currently can and do switch their mortgage and this number is growing. BPFI welcomes the opportunity to improve the switching process and recommends the amendment of requirements that currently limit the adoption of more consumer centric approaches, particularly in relation to documentation. BPFI looks forward to further engagement with all impacted stakeholders in relation to mortgage switching.