Stellungnahme DK zu BCBS Consultative Document No. 246 “Supervisory framework for measuring and controlling large exposures”
The German Banking Industry Committee generally welcomes the fact that the Basel Committee based the present proposal on existing and tested and tried processes pertaining to own funds requirements but also to the field of large exposures.
The Committee’s proposals are explicitly geared towards internationally active banks. At the same time, more likely than not, national supervisors will extend the regulatory scope to include smaller banks, too. Hence, it would be judicious to equally take the interests of smaller banks into account.
Under the current proposals, when it comes to the calculation of exposure values, the Committee gives preference to simpler approaches. We are of the opinion that this preference is unwarranted. For the banks concerned, this leads to a divergence between the regulatory capital framework and the large exposures framework. In lieu of this, banks should be able to use consistent approaches for both purposes and it should remain within their discretion to choose advanced methods, i.e. internal models for the calculation of the exposure values.
The Consultation Paper remains silent on the treatment of intragroup exposures. Notwithstanding the foregoing, we would like to emphasize our firm belief that there shall and must not be any impediment to the free flow of capital and liquidity within a banking group. Any restriction would have negative repercussions for liquidity management and capital management within a banking group. Hence, we consider the exemption of these exposures from the large exposure limits as justified and necessary. […]