- Lorenzo Bini Smaghi – President, Société Générale
- Ignazio Angeloni – Member of the Supervisory Board, ECB
- Elke König Chair – Single Resolution Board (SRB)
- Robert Ophèle – Second Deputy Governor, Banque de France
- Luigi Federico Signorini – Deputy Governor and Member of the Governing Board, Banca d’Italia
- Jérôme Brunel – Head of Public Affairs, Crédit Agricole S.A.
- Aurelio Maccario – Head of Group Regulatory Affairs, Unicredit S.P.A.
- Ignacio Redondo – General Counsel, CaixaBank, S.A.
Too many national options and discretions exist and have to be eliminated
In a Banking Union, banks should be supervised on the basis of a single set of rules. The prudentially harmonised application of Options and National Discretions (ONDs) is an essential task: it is the condition of a single rulebook consistently applied by all supervisors.
The ECB compiled a list of approximately 160 ONDs in the Capital Requirements Directive IV (CRD IV) and Capital Requirements Regulation (CRR). The ECB is preparing a formal legal text stipulating the way the ECB intends to exercise around 100 ONDs. A public consultation should be launched in November.
Up to 40 ONDs are in the hands of either the governments or the parliaments of the Member States. This is why it is important that the prerogatives of national legislation are exercised in a way that conforms to the letter and the spirit of the Banking Union.
On the implementation of this set of rules, one has to take into account the need to phase in these changes so they are not disruptive. In addition, the single rulebook has to preserve the diversity of the different forms and business models of banks.
Harmonizing accounting and corporate governance rules is also necessary. Good supervision needs good, reliable and compatible data. In Europe, the adoption of the IFRS is limited to some countries, and national rules are still widely used, particularly for smaller banks. This makes a big difference to the valuation of certain assets, which undermines comparability and might distort action.
In addition, a number of banks, while meeting national requirements, do not comply with EU or international best practices with regard to governance. This can obscure or even encourage malpractice. Progressing towards more trust in the European banking system requires some harmonisation in the area of corporate governance. The Single Supervisory Mechanism is close to completing a thematic review on risk governance and risk appetite in the 123 banks that it directly supervises.
Another major challenge for the SSM is the mismatch between the regulators and market’ timing. Market reactions to new prudential regulatory constraints are much faster than the phase in arrangements defined by the regulator. This is reducing considerably the banks’ ability to adjust to the new regulatory constraints. The transition period for the implementation of regulatory constraints is indeed quasi inexistent. In such a context and taking into account the importance of banking intermediation in the Eurozone compared to the banking intermediation in the US, many speakers stated that caution should therefore apply in the calibration of the forthcoming regulatory decisions in order to avoid impacts on the real economy. It was also stated that a strategic view of the role that a stable and sound financial system should play in supporting the Eurozone economy is lacking and is urgently needed.
In a Banking Union, banks should also be supervised on a global geographical basis, eliminating the ring-fencing of capital and/or liquidity on a national basis
It seems nevertheless that we are still far from such a completion: pillar 2 requirements have actually increased and not reduced; in addition liquidity waivers are granted in a restrictive manner. According to a regulator, even if we could regret it, the banking system is likely to stay fragmented and it is nevertheless understandable at the still preliminary phase of our Banking Union:
- The SSM needs to demonstrate its efficiency in supervising banks on a really homogeneous euro-zone basis; its organization, based on Joint Supervisory Teams should address this issue;
- The resolution mechanisms introduced by the Bank Recovery and Resolution Directive ( BRRD) and the SRM need to demonstrate its workability;
- And ultimately there is a clear need to introduce a single deposit guaranty mechanism and fund. As long as the guaranty is covered on a national basis, we will keep German, Italian or French banks but no truly European banks.
Recent developments and challenges of the Single Resolution Board (SRB)
The SRB is in place and will soon be responsible together with the national authorities for resolution planning and for assessing resolvability. This is essential for addressing obstacles and trying to solve those obstacles to resolution.
One of the challenges of the SRB is to set up an appropriate co-operation with the national resolution authorities. Some of them are national authorities in the making, as they are just actually being established right now. Another challenge is to achieve a close co-operation with the ECB, because there needs to be a seamless co-operation between SSM and SRB.
Co-operation is also needed with the other stakeholders, such as the Commission, the Council and the European Parliament. Whilst addressing obstacles to resolution, it is notably an international business, even more so as larger banking groups within the authorities outside the Eurozone are involved, and there are also some outsiders to consider, such as the Bank of England and others.
Within the Banking Union, there is one supervisor for significant banks and one resolution authority. Therefore there is a strong argument for a single point of entry approach in terms of resolution. Nonetheless, when it comes to resolution, this may involve specific entity consideration at the same time. A consolidated approach is probably the model for a broad future, even though the MREL part of the regulatory arrangements needs to be set on an entity basis.
The SRB is now defining its policies, including how the MREL will be viewed. It is preparing for 1 January 2016, when it will take over responsibility for, what hopefully will not happen, actually enacting resolution schemes in cases of failing banks.
A common Deposit Guarantee Scheme (DGS) should be the third pillar of a fully-fledged Banking Union alongside bank supervision and resolution. As the current set-up with national deposit guarantee schemes remains vulnerable to large local shocks, common deposit insurance would increase resilience against future crises. A pan-European DGS should be a priority in the future, once the current banking reforms have been implemented and the Resolution Funds built up.
SummaryA speaker opened the discussion by reminding the audience of two aspects of the Banking Union: the institutional path and the legislative one.
- The institutional path is the Single Supervisory Mechanism (SSM), which is operational and now doing its first supervisory cycle. The SSM has a clear mission to ensure the safety and soundness of banks, and to contribute to the financial integration of the euro area. There is also the Single Resolution Mechanism (SRM), which is well on the way to start business at the beginning of next year.
- The legislative path is the Capital Requirements Directive IV (CRD IV) and Capital Requirements Regulation (CRR). Compared to the past, the fact that a Regulation that is directly applicable is in place, is a substantial improvement.
Panellists identified the objectives to be pursued to achieve a successful SSM. A decision maker stressed for example that even if the current regulatory platform is powerful and adequate, it still requires further work, in order to realise the major objectives of the SSM: setting up a single rule book in order to ensure a level playing field, implementing a harmonious working of supervision in the SSM area and creating a framework for truly European banking markets, and truly European banks.
It was pointed out that the arduous goal of the harmonization process is to ensure a consistent and effective action at the euro area level, while coping with 19 different legal and accounting frameworks and many different banking markets.
A large part of the discussion was dedicated to the ongoing work of the SSM on options and national discretions.
1. Too many national options and discretions exist and have to be eliminated
In a Banking Union, banks should be supervised on the basis of a single set of rules. All the speakers agreed that, the presence of Options and National Discretions (ONDs) in the EU legal prudential framework1 have material effects on the level of prudence of the framework and on the comparability of for instance capital ratios, which make it harder for markets and the public to gauge banks' capital strength. Moreover, the SSM cannot supervise banks efficiently on a level playing field and from a truly single perspective if significant divergences effectively remain in the way EU laws are applied nationally.
The speakers from the industry explained that the harmonised application of ONDs could be costly for banks. Therefore there is a need for a sustainable transition to achieve a single rulebook.
Reducing the member states' margin of flexibility is a necessity for the sound working of the SSM
One well-known particular problem in the industry and supervisory community is that the CRD IV and the CRR grant Member States broad discretion in applying a wide range of norms. Such flexibility was given to the legislator at a time when the creation of a single European supervisor was not foreseen.
A regulator stated that these discretions, the so-called ONDs leave room, in the SSM area, for significant cross-border differences in a variety of regulatory provisions, many of which - for example those regarding the calculation of capital and liquidity buffers, are of key importance from a prudential viewpoint. They have a strong impact, affecting the quantity and the quality of capital, the liquidity and the distribution of liquidity within the groups, the large exposures and limits within the groups.
The ECB has identified approximately 160 ONDs. These include a number of options (up to 40) enshrined in national legislation over which the SSM has no power. Indeed, there is the possibility for one member state to enact legislation in the banking and financial field in its country that may have a global impact on the whole Banking Union. These options can be exercised by the member states, through national legislation. The supervisor himself cannot intervene directly and autonomously there. In some cases, there can be a conflict between the laws that are enacted by the national authorities and the proper working of the Banking Union.
In such a context, a speaker emphasised that national legislators and authorities have to realise that whatever the margins of manoeuvre they may still have in the regulatory field, their legislation has to be exercised in a way that is compatible with the working of the SSM and the rest of the Banking Union. It is therefore crucial that national legislators should share the SSM objectives of supervisory effectiveness and consistency.
According to another regulator, the starting point regarding ONDs is the way the own funds are defined. It is extremely important to make their calibrations converge as soon as possible. At the same time, he added that there must be no real barrier to the movement of liquidity and capital among different legal entities in the Banking Union.
The need to phase in these changes so they are not disruptive
A panellist highlighted a crucial point to keep in mind: a real and effective single rule book is a desirable goal, but it has to be achieved avoiding a “regulatory rally”. Otherwise it could distract banks from focusing on their mission to help economic sustainable growth.
A regulator pointed out the necessity to take into account the prudential considerations and adequate gradation that all these changes must have so they are not disruptive and can preserve the safe and sound working of the banking system. For now, he confirmed that these ONDs provide supervisors and national member states with a certain margin of flexibility in applying these norms according to their national conditions and situations, or the peculiarities of national markets. The panellist insisted on the fact that these divergences, having very disruptive effects, are indeed an obstacle to ensuring the supervisory neutrality, safety and soundness of large banks especially and more broadly towards any further banking integration in the SSM area.
An industry representative explained why ONDs should not be eliminated altogether. Indeed, before doing so, the SSM need to understand and assess the Member States' justifications for national discretion or options, to help determine if they are appropriate or not and their impacts for the entire banking sector. He insisted on the dangerous temptation to consider that no discretion makes sense, precisely because some of them are relevant. In this way, the assessment should include the two following dimensions: (i) the legal environment because tax law which can differ from one country to another and (ii) the coexistence of different business models in the banking landscape. The panellist recalled the importance of considering that Member States' retail banking markets are not homogeneous and that there may be areas of regulation where it is important to maintain differences and grant national discretion given the local specificities.
The approach that “the stricter the better” is true most of the time but not always. This is why a careful analysis must be conducted to ensure that becoming stricter does not hamper the needs of business and profitability.
Another industry representative agreed that institutional changes are generally expected. The events of the last few years clearly demonstrated the real need for harmonisation and integration between different supervisory regimes, because this was significantly affecting the way business was conducted on a daily basis in terms of costs of compliance, legal costs, etc. He stressed that the single supervision requires a smooth transition based on legal certainty and continuity in line with the legitimate expectations of bank management and investors. Any changes in the way Pillar II is calculated, assuming that nothing has changed in the bank in terms of risk profile, could be extremely disruptive for the bank, for the investors and for the stock markets, because Pillar II requirements are binding and a bank cannot deliver yields or distribute dividends if it does not fulfil those requirements.
More generally, on the ONDs exercise, a regulator stressed that despite its complexity, efforts will be made with respect to legitimate expectations. The timing is short for this exercise; it will be a matter of a few months. This policy package is being translated into a legal package, composed of an ECB regulation for general ONDs, and internal guidance laying down stances and specifications for case-by-case ONDs. The speaker added that the resulting draft regulation will be subject to a public consultation, to be launched in November. In this context, any input from the industry would be very welcome.
Harmonizing accounting and corporate governance rules is also necessary
One further issue mentioned was the accounting standards. Indeed, a panellist pointed out that good supervision also needs good, reliable and compatible data. In Europe, the adoption of the IFRS is limited to some countries, and national rules are still widely used, particularly for smaller banks. This makes a big difference to the valuation of certain assets, which undermines comparability and might distort action. He considered that the time has now come for the accounting issue to be placed first on the national decision makers' agenda to help to ensure a streamlined management of these critical aspects of banking supervision.
Moreover, this speaker pointed out another issue related to the single rulebook: the fit and proper requirement. Skills such as integrity, reputation and time commitment are indeed prerequisites for directors to ensure the prudent management of banks. However, this corporate governance area is still regulated by national laws to a large extent. The wide ranges of national rules on how to put this into practice are very different. In some countries, supervisors have ample discretion in these rules to exercise judgement. In other countries, in theory at least, board members can be disqualified only after a criminal conviction. Ideally, there should be, in the SSM area, a middle way, between too much formality and too much absolute discretion. This may impinge on constitutional rights and, from the point of view of the supervisor, might blur the distinction between supervisory decisions and banks' choices.
2. In a Banking Union, banks should also be supervised on a global geographical basis, eliminating the ring-fencing of capital and/or liquidity on a national basis.
A central banker explained that there are two ways of implementing capital ring-fencing: through Pillar 2 requirements and through the large exposure regulation applied without waivers to intra-group exposures.
- Solvency requirements are expressed both on a consolidated and on a solo basis; while the focus is always clearly put on the consolidated level, it could be fully legitimate to also impose Pillar 2 requirements on a sub-consolidated basis. It could, for example, be the case when different business lines are encapsulated in separate entities. But putting numerous high requirements on a pure national basis would limit the circulation of capital and disturb the adequate allocation of capital according to the expected Return on Equity.
- Focusing on consolidated situations means also granting waivers to intra-group large exposures on a solo basis. While such waivers are frequent on a national basis, they are more controversial on a trans-national basis, but in a banking union they should become the new norm; they demonstrate the solidarity inside a banking group and are a way of optimizing the use of liquidity.
Then this speaker discussed the liquidity issue, which is key. He took the example of banking groups having excess liquidity in one country and unable to use it in another country and obliged to go to the central bank facility. In order to remove such barriers, inside the banking union, we need to grant liquidity waivers and apply the Liquidity Coverage Ratio regulation on a consolidated basis provided the conditions are fulfilled but irrespective of national intra-eurozone boundaries.
We are still far from such a completion:
As long these new approaches are not fully implemented, the Banking Union will not be completed and the advantages of such a Union will not be reaped. It seems nevertheless that we are still far from such a completion: pillar 2 requirements have actually increased and not reduced; in addition liquidity waivers are granted in a restrictive manner.
The speaker stated that even if we could regret it, it is nevertheless understandable at the still preliminary phase of our Banking Union:
- The SSM needs to demonstrate its efficiency in supervising banks on a really homogeneous euro-zone basis; its organization, based on Joint Supervisory Teams should address this issue;
- The resolution mechanisms introduced by the BRRD and the SRM need to demonstrate its workability;
- And ultimately there is a clear need to introduce a single deposit guaranty mechanism and fund. As long as the guaranty is covered on a national basis, we will keep German, Italian or French banks but no truly European banks and, according to this speaker, it will be legitimate to keep some sort of ring-fencing of capital and liquidity.
According to another regulator, everything cannot be achieved at the same time but we should keep in mind what we are heading for and make regular progress in that direction, with the objective to achieve full integration and a truly consolidated approach to supervision.
3. Removing regulatory uncertainties to avoid any further impacts on EU recovery
A banker highlighted some further elements for the panel's consideration. First, the European banking system is not an island: it is closely linked to the rest of the world. He feared that some of the uncertainties or some of the regulatory elements which are not yet settled could place the European banking system in a disadvantaged situation in the global competition. In the US, the legislation is more or less fixed. The UK is a little more advanced than continental Europe which is in a process that is inevitably gradual, but this adds uncertainty to the banking system in continental Europe. According to him, there should therefore be more certainties about the process and the timing. A strategic view of the role that a stable and sound financial system should play in supporting the Eurozone economy is lacking.
An additional element is that the economies are gradually recovering in continental Europe. However, uncertainties in the regulatory framework may not be helping this slight recovery. Other macro policies have, to some extent, exhausted their role - monetary policy is at zero. Given such an environment, macro and international, he underlined the importance of having a clear roadmap of the timing process.
A public decision maker recognized that there is an international tendency that extends to Europe, towards increasing capital requirements. According to him this is consistent with the lessons of the crisis. In the academic analyses that are available, views about the ultimate result differ significantly. What is the right capitalisation of a safe and sound banking system? This is unclear and usable input from academics would be welcome. Within the supervisory profession there are also different views. But this speaker recognized that the industry and the rest of the world need reliable indications about the capital end point and the regulatory end point. A wave of changes followed the crisis: it is now crucial according to him that the industry should have some lasting stability.
In addition, the panellist pointed out that by the end of 2015 the ECB will have in place a single Supervisory Review and Evaluation Process (SREP) approach, judging the soundness of banks according to business model sustainability, robustness of governance and controls, risks for capital, and risks for liquidity and funding. This process will culminate in a new SREP-letter, defining supervisory requirements – including Pillar 2 capital – for the next 12 months.
Another major challenge for the SSM is the mismatch between the regulators and market' timing. Caution should therefore apply in the calibration of the forthcoming regulatory decisions
An industry representative stated that market reactions to new prudential regulatory constraints are much faster than the phase in arrangements defined by the regulator. This is reducing considerably the banks' ability to adjust to the new regulatory constraints. The transition period for the implementation of regulatory constraints is inexistent, because of the markets' immediate anticipations.
He noted that some important forthcoming regulatory issues may affect the real economy in the euro area, and also in the European Union Over the next few years there are a number of heavy regulatory caps that will come into force. The most relevant ones are TLAC for EU SIFIs and MREL for all the European banks; the IFRS 9 in terms of accounting standards; the revision of sovereign risk or the treatment of sovereign exposures in the balance sheets of banks; and the revision of the risk computation framework. All of these issues sooner or later will result in higher capital requirements for the large European banks.
It is not a matter of disputing if banks need to hold more or less capital versus the current situation, he said. Current capital levels will probably have to increase over the next year. But it is important to have clarity and guidance on what is the target capital ratio so that a CEO can commit before its stakeholders consider everything planned for the next year. This is something which is still probably unclear.
The speakers agreed to a large extent that any new requirement must be immediately taken into account by the markets. For instance, with regard to the definition of core equity Tier 1, the difference between the fully loaded ratio and the actual one is around 70 basis points (on the Eurozone basis). A regulator stressed that, when the rules change, such as Pillar II, the distance between the trigger of some changes in the remuneration of products will change dramatically, because there are already these 70 points to cover. This means that there must be caution when making the decision, because the conservation buffer is also phased in, and the systemic buffer for large banks is phased in too. The IFRS 9 changes mean that between 30 and 50 basis points of changes can be expected on the Common Equity Tier 1 ratio.
The regulator considered that regarding the particular macro environment mentioned, and taking into account the importance of banking intermediation in the Eurozone compared to the banking intermediation in the US, prudence is a necessity. The SSM will help to make the transition. But, with regard to the discussion about the pure macro buffer, not the systemic one, whilst the architecture is in place, he estimated that there is really “no urgency” to trigger them. He stated that there is no way the countercyclical buffer could be activated right now, because unfortunately it is at the bottom, not the top of the cycle. This will come when the other parameters are fixed.
A mutual supervisory culture is needed, respectful of the diversity of the banking business models and national market specificities
An industry representative put forward the view that there is a will to build up a mutual supervisory culture. However, this is a time-consuming process which requires an in-depth dialogue between the supervisors and the industry both on the diversity of banking business models, which needs to be preserved, and on national market specificities. National markets are indeed very different from one country to another due to “stubborn” realities. The panellist took the example of France, where nearly 90% of the mortgage market is based on a fixed interest rate mortgage credit. The forthcoming rules stemming from Basel will encourage the banks to go for variable interest rate risks, which is against consumers' and borrowers' habits in the French market and contrary to the equilibrium that has been reached, despite the fact that this French mortgage market is extremely safe. This is an example to show that the harmonisation of supervision does not mean that national markets are the same in all the countries of the SSM area.
Some non-SSM countries have adopted a defensive mode versus the SSM
An industry representative highlighted the challenging relationship between the SSM and non SSM supervisors: he reminded the audience in particular that the SRM is a European Union institution, and the SSM is the Eurozone supervisory mechanism. Recently, some non-SSM countries have adopted a defensive mode versus the SSM. He pointed out that the SSM is keen to integrate and adopt a pan-euro area approach in dealing with the issues. But the non-SSM countries now need to confront the more relevant players in terms of scope of reference. This clearly raises some problems. Some ring-fencing issues within the euro area should be resolved, but there is a risk of exacerbating trouble outside the SSM, he added.
4. Recent developments and challenges of the Single Resolution Board (SRB)
The Banking Union is a way to better protect taxpayers from the cost of bank rescues. The SRM is the second leg of the Banking Union – the SSM is the first one).
The SRB is the resolution authority within the European Banking Union and represents a key element of the SRM. Its mission is to ensure an orderly resolution of failing banks with a minimum impact on the real economy and public finances of the participating Member States and beyond. The Board will prepare resolution plans and will carry out the resolution of banks in trouble, whenever one of them fails or is likely to fail. The Board will also be in charge of the Single Resolution Fund (SRF), a pool of money financed by the banking sector which will be set up to ensure that medium-term funding support is available while a credit institution is being restructured.
A regulator stated that within the Banking Union, there is one supervisor for large cross border banks and one resolution authority. Therefore there is a strong argument for a single point of entry approach in terms of resolution. Nonetheless, when it comes to resolution, this may involve specific entity consideration at the same time.
According to this speaker, a consolidated approach is probably the model for a broad future, but may not be the appropriate one for the current resolution topics. The MREL part of the regulatory arrangements needs notably to be set on an entity basis. Therefore, there should be at least a pause before moving forward on to a consolidated approach for resolution.
The SRM and the SRB are in place. The SRB has been in place since January 2015 and is already responsible together with the national authorities for resolution planning and for assessing resolvability. This is essential for addressing obstacles and trying to remove those obstacles to resolution.
One of the challenges of the SRB is to set up an appropriate co-operation with the national resolution authorities before it is fully responsible for resolution as of 1 January 2016. Some of them are national authorities in the making, as they are just actually being established right now.
Another challenge is to achieve a better co-operation with the ECB, because there needs to be a seamless co-operation between SSM and SRB.
Co-operation is also needed with the other stakeholders, such as the European Commission, the European Council and the European Parliament, even more so as larger banking groups within the authorities outside the Eurozone are involved. There are also other stakeholders outside the euro area to be considered such as the Bank of England, the FDIC, the FED etc.
It was noted that the only reasonable solution to avoid ring-fencing issues outside the Eurozone is to achieve an effective co-operation between the supervisors and the resolution authorities. In addition, the idea that capital and other eligible instruments providing loss- absorbing capacity need to be pre-positioned and adequately spread within a group is essential in this respect.
The SRB is now defining its policies, including how to set the MREL. It is preparing for 1 January 2016, when it will take over responsibility for, what hopefully will not happen, actually enacting resolution schemes in cases of failing banks.
The rules of resolution are that if a bank is failing or likely to fail, a private solution comes first. If there is no private solution, the next step would be to consider that insolvency is the next option. Only if resolution is expected to deliver a better result, will the bank go into resolution and within resolution there is a broad tool box once the Bank Recovery and Resolution Directive (BRRD) is implemented in all the member states. It should however be noted that at present the BRRD has not been adopted in all member states.
The SRF will not solve all the evils of the banking sector in Europe. It is hoped that in eight years' time when the Resolution Fund is fully established, the Fund will be fully financed, and that the SRB will not have had to investing in it.
Relationships between micro and macro-prudential supervisory policies are important issues
A regulator stated that it is important to have some reflection on the interplay between the two aspects of prudential supervision. Major trends and risks in the financial sector or the macro economy should not escape the attention of banking supervisors. Macro prudential supervision has some unique challenges, and one of these challenges is that in good times macro and micro go in the same direction. Thus, what is prudent from the micro point of view is also, without any doubt, prudent from the macro point of view.
But in difficult times there is more of a trade-off. There is a need to have an evaluation of “the overall prudential stance”. Tensions may arise because micro prudential supervision does not necessarily internalise the potential adverse effects that it may have on the macroeconomic scale. So, frictions between micro and macro prudential policies are most likely to emerge during downturns. In macro terms, consideration of the fiscal stance is customary. Given the way that prudential supervision has changed in the past few years, gives some idea of how essential the prudential stance is. This is something that is not just important from the micro point of view, from the safety or the soundness of the individual bank, but it is something that has a macro economic effect. The SSM has started to work on those issues.
Towards a European Deposit Guarantee Scheme (EDGS)?
A regulator recalled that a EDGS should be the third pillar of a fully-fledged Banking Union alongside bank supervision and resolution. As the current set-up with national deposit guarantee schemes remains vulnerable to large local shocks, common deposit insurance should increase resilience against future crises.
The public decision maker stressed that the pan-EDGS could be an option in the future, once the current banking reforms have implemented and the Resolution Funds built up.
1 Material and controversial ONDs include, for instance, the treatment of insurance holdings within conglomerates for the purpose of calculating the CRR capital ratios (Article 49(1) of the CRR), as well as the longer phasing-in of the deduction of deferred tax assets ('DTAs') relying on future profitability that existed prior to 2014 (Article 478(3) of the CRR).
By I. Angeloni - Member of the Supervisory Board, European Central Bank (ECB)
By L. Federico Signorini, Deputy Governor and Member of the Governing Board, Banca d'Italia
By I. Redondo Andreu - General Counsel, CaixaBank, S.A.
By R. Ophèle - Second Deputy Governor, Banque de France
By E. König - Chair, Single Resolution Board (SRB)
By L. Bini Smaghi - President, Société Générale