Stellungnahme DK zu “Draft Guidelines on capital measures for foreign currency lending to unhedged borrowers in the SREP”
As part of a company’s credit assessment, in the field of corporate finance, foreign currency risks have to be identified and evaluated in the same way as other material risks. This does not present a new requirement. Instead, it has always been part and parcel of a bank’s risk analysis process. Based on the foregoing, we advocate in favour of a solution where the “foreign currency risk“ shall not be incorporated under Pillar II as a separate risk type.
Furthermore, we would like to point out that, both in this Consultation Paper as well as in the recommendation of the European Systemic Risk Board it is being emphasised that the regulatory measures are primarily geared towards private individuals - who for speculation reasons or, moreover, in order to reduce their interest burden - take out loans in another currency (that differs from their current earnings). Nevertheless, the scope of application of the present Consultation paper is not limited to private individuals. From our point of view, this approach is worth reviewing. In our view, an application of the requirements to internationally active companies or, moreover, corporate groups is not feasible. Hence, we advocate in favour of a solution where the scope of application is limited to private individuals. As an alternative regulatory choice, there is an absolute need to specify that companies which enter foreign currency risk without any speculative intent and which manage their foreign currency risks correspondingly, are by definition considered “hedged borrowers”. […]