Notification template for Article 131 CRD - Other Systemically Im-portant Institutions (O-SII)
Please send this template to
·notifications@esrb.europa.eu when notifying the ESRB;
·macropru.notifications@ecb.europa.eu when notifying the ECB;
·notifications@eba.europa.eu when notifying the EBA.
Emailing this template to the above-mentioned addresses constitutes an official notification, no further official letter is required. In order to facilitate the work of the notified authorities, please send the notification template in a format that allows electronically copying the information.
1. Notifying national authority | |
1.1 Name of the notifying author-ity | Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht - BaFin) |
2. Description of the measure | |
2.1 Concerned in-stitution or group of institutions | On which institution(s) is the measure applied (name and LEI code)? Rank 1. O-SII Institution Deutsche Bank AGLEI-Code 7LTWFZYICNSX8D621K86
529900Z3J0N6S0F7CT25 The buffer is set on the highest level of consolidation. |
2.2 Level of the buffer applied | What is the level of the buffer (in %) applied to the institution(s)? Rank 1. O-SII Institution O-SII buffer Deutsche Bank AG 2.00% 2. Commerzbank AG 1.50% 3. DZ Bank AG, Zentral-Genossenschaftsbank 1.00% 4. Unicredit Bank AG 1.00% 5. Landesbank Baden-Württemberg 1.00% 6. Landesbank Hessen-Thüringen Girozentrale 1.00% 7. Bayerische Landesbank 1.00% 8. Norddeutsche Landesbank Girozentrale 1.00% 9. NRW.Bank 0.50% 10. ING DiBa AG 0.50% 11. DekaBank Deutsche Girozentrale 0.50% 12. Volkswagen Bank GmbH 0.50% 13. Landwirtschaftliche Rentenbank 0.50% |
1 The identification of the listed institution as O-SII is still pending German administrative procedure.
2.3 Name of the EU ultimate par-ent institution | Please provide the name and the LEI code of the EU ultimate parent institution of the group of each of the concerned institutions, in case the EU ultimate parent institution is not the concerned institution itself. O-SII Institution Parent Company LEI-Code (parent company) UniCredit Bank AG ING-Diba AG Unicredit S.p.A. ING Groep N.V 549300TRUWO2CD2G5692 549300NYKK9MWM7GGW15 |
2.4 Names of sub-sidiaries | If any of the concerned institutions is a parent institution and the buffer is applied on a (sub)consoli-dated level, please name the subsidiaries of the institution that are notified as O-SIIs (please give name and LEI code). à please see the list in the Annex 1 to the notification template |
3. Timing of the measure | |
3.1 Timing of the Decision | What is the date of the official decision? For SSM countries when notifying the ECB: provide the date when the decision referred to in Article 5 of the SSMR shall be taken. 19 November 2018 |
3.2 Timing of the Publication | What is the date of publication of the notified measure? 20 December 2018 |
3.3 Disclosure | Information about the communication strategy of the notified measure to the market. à The designated institutions and their respective O-SII capital buffer requirements will be published on the internet webpage of the BaFin after the administrative procedure will have been completed. |
3.4 Timing of Ap-plication | What is the intended date of activation (i.e. as of which date shall the measure be applicable)? 1 January 2019 |
3.5 Phasing in | What is the intended timeline for the phase-in of the measure? O-SII buffer requirements per institu- tion during phase-in periodFrom From FromRank O-SII Institution 1 Jan 2017 1 Jan 2018 1 Jan 2019 From 1 Jan 2020 From 1 Jan 2021 0.66%1.32%2.00%2.00%2.00% 1. Deutsche Bank AG
0.33% 0.66% 1.00% 1.00% 1.00%
0.16% 0.32% 0.50% 0.50% 0.50% 0.16% 0.32% 0.50% 0.50% 0.50% 0.16% 0.32% 0.50% 0.50% 0.50% --- --- 0.16% 0.32% 0.50% |
2 As a result of the German method an unchanged capital buffer of 1.5% is required to the institution. As part of the administra-tive procedure BaFin has to assess the principle of proportionality. The institution has continuously reduced its systemic im-portance in the recent years and has demonstrated to BaFin that it has concrete plans for a further reduction. Now, It is likely that the overall score of the Bank will go below the lower buffer-bucked-threshold. Therefore it would be disproportionate in the administrative procedure, in accordance with the principle of proportionality, if the institution now had to build up the full capital buffer of 1.5%.
13. Landwirtschaftliche Rentenbank 0.16% 0.32% 0.50% 0.50% 0.50% | |
3.6 Review of the measure | When will the measure be reviewed (Article 131(6) and 131(12) specify that the buffer, the identifica-tion of O-SIIs and the allocation into subcategories must be reviewed at least annually)? à The necessity and level of O-SII buffers will be reviewed annually. (Section 10g (3) of the German Banking Act; Article 131(6) of the CRD IV). |
4. Reason for O-SII identification and activation of the O-SII buffer | |
4.1 Scores of con-cerned institution or group of insti-tutions, as per EBA guidelines on the assess-ment of O-SIIs (Article 131.3) | Please list here the name, overall scores, category scores, and indicator values of the identified O-SIIs related to
à In step 1 of the identification process (EBA/GL/2014/10, Title II) automatically identified O-SIIs (score ≥ 350 bps): RankO-SII InstitutionOverall scoreSizeInterconnec- Complexity tedness Substitutability 1. Deutsche Bank AG
2634.89 726.40 515.15 4. 447.22 1941.64 593.34 546.97 390.29 1837.04 548.60 894.74 416.77 5152.93 1607.96 871.82 891.83 344.66 274.24 646.39 335.43 Unicredit Bank AG à In step 2 of the identification process (EBA/GL/2014/10, Title III: Supervisory Assessment) identified O-SIIs (score ≥ 100 bps and/or expert judgment): RankO-SII Institution Overall Size scoreInterconnec- Complexity Substitu-tedness tability 1. Deutsche Bank AG
106.26 103.42 296.44 24.99 0.19 |
Due to a restructuring of the Volkswagen Financial Services AG, Volkswagen Bank GmbH is a newly designated O-SII. When notifying the ECB or EBA, please provide relevant information (methodology, calculations and formulas, data sources, information set used for denominators) in a separate Excel file. methodology: à We apply the methodology as described in EBA/GL/2014/10, Title II. calculations and formulas: à see Annex 2 to the notification template data sources: à The data used to calculate the scores has been obtained mainly from:
information set used for denominators: à The denominators used to calculate the scores are itself calculated by summing up all values of all institutes in Germany of the respective indicator. | |
4.2 Methodology and indicators used for designa-tion of the O-SII (Article 131.3) | Please provide information on: a. whether you followed the EBA guidelines on the assessment of O-SIIs à The identification of the O-SIIs is based on EBA/GL/2014/10. b. which threshold score has been set to identify O-SIIs à Scores in step 1 of the identification process (EBA/GL/2014/10 Title II "Scoring methodol-ogy for the assessment of the O-SIIs"): All institutions with a score of ≥ 350bps applying EBA/GL/2014/10 Title II were automatically identified as O-SIIs. Scores in step 2 of the identification process (EBA/GL/2014/10 Title III "Supervisory Assess-ment of O-SIIs"): All institutions which received a score of ≥ 100bps in the national scoring model within the assessment according to EBA/GL/2014/10 Title III were additionally identi-fied as an O-SII by supervisory assessment. This calculation was corroborated by an expert judgment. c. which overall score is attributed to the O-SIIs à see section 4.1 d. which of the optional indicators have been used to justify supervisory assessment decisions. if any, and what are the scores à Indicators used for EBA/GL/2014/10, Title III: Category SizeNationally expanded indicators · Total assets + contingent liabilitiesEconomic im-portance (including substitutability /
|
financial system | · | Number of domestic payment transac- |
infrastructure) | tions processed for non-banks | |
· | Private sector deposits in Germany | |
· | Private sector loans in Germany | |
Cross-border activi- | · | Claims from foreign non-banks |
ties (including com- | Liabilities to foreign non-banks | |
· | ||
plexity) | Claims from foreign banks | |
· | ||
· | Liabilities to foreign banks | |
· | Number of legally independent subsidi- | |
aries in Germany and abroad | ||
· | Receivables from derivatives in trading | |
portfolio | ||
· | Liabilities from derivatives in trading | |
portfolio | ||
Interconnectedness | · | Liabilities to banks |
· | Liabilities to insurers and other financial | |
institutions in Germany | ||
· | Receivables from banks | |
· | Receivables from insurers and other fi- | |
nancial institutions in Germany | ||
· | Debt securities outstanding |
e. why these optional indicators are relevant for the Member State
à
o In the size category, contingent liabilities have been added to the total assets indicator in order to include off-balance sheet risks.
o In the category economic importance for the EEA and the Federal Republic of Germany (substitutability/infrastructure of the financial institution), the number of payment transac-tions processed has been added as an indicator, in addition to their volume. The number of transactions helps to determine whether an institution processes only a few, but larger transactions. By including the number of indirect participants connected via Target2 as another indicator, the institutions' infrastructural function in the Target2 processes can be mapped.
o In the category cross-border activity (complexity/cross-border activity), cross-jurisdic-tional claims and liabilities have been broken down into receivables from and liabilities to foreign banks and non-banks. This creates a more differentiated picture of the institu-tions' cross-border activities. The number of legally independent subsidiaries (institu-tions) in Germany and abroad has been added as another indicator in order to reflect the complexity of institutions' organisational structure.
o In the category interconnectedness with the financial system (interconnectedness), intra-financial system assets and liabilities have been broken down into receivables from and liabilities to banks on the one hand and insurance undertakings and other financial insti-tutions on the other hand. Due to the unavailability of data in the banking supervisory reporting system, the indicator intra-financial system liabilities and assets is restricted to Germany. The distinction between banks and other financial intermediaries gives a more accurate picture of the various contagion channels within the financial system.
f. why the bank is systemically important in terms of those particular optional indicators à The logic of the scoring model according to EBA/GL/2014/10, Title II, is applied here: the relevance of the respective institution is expressed by the value of its respective indicator in
Attachments
- Original document
- Permalink
Disclaimer
ESRB - European Systemic Risk Board published this content on 25 January 2019 and is solely responsible for the information contained herein. Distributed by Public, unedited and unaltered, on 25 January 2019 12:13:03 UTC
