4. Business model and management
Sector
concentrations
in loan portfolio
The aim of this indicator is to
measure the risk of incurring
substantial credit losses as a result
of a downturn in a specific sector
of the economy to which an
institution is highly exposed.
(+)
A higher
value
indicates
higher risk
Large exposures
Where:
‘large exposures’ as defined in
Regulation (EU) No 575/2013;
and
‘eligible capital’ as defined in
point 71 in Article 4(1) of
Regulation (EU) No 575/2013
The aim of this indicator is to
measure the risk of incurring
substantial credit losses as a result
of the failure of an individual
counterparty or group of
connected counterparties.
(+)
A higher
value
indicates
higher risk
GUIDELINES ON METHODS FOR CALCULATING CONTRIBUTIONS TO DGS
42
Excessive
balance sheet
growth ratio
This indicator measures the
growth rate of the institution’s
balance sheet. Unsustainably high
growth might indicate higher risk.
Off-balance-sheet items and their
growth should also be included.
When setting thresholds for this
indicator it is necessary to
determine what level of growth is
considered too risky. This should
take due account of the growth of
the economy in a given Member
State or national banking sector.
When using this indicator special
rules should be defined for new
institutions and for entities which
have been involved in mergers and
acquisitions over the last few
years.
To avoid including one-off events in
calculating contributions, an
average growth observed during
the last 3 years should be used.
(+)
Values
exceeding a
predefined
level of
excessive
growth
indicate
higher risk
Return on
equity (RoE)
This ratio measures institutions’
ability to generate profits to
shareholders from the capital these
have invested in the institution. A
business model which is able to
generate high and stable returns
indicates reduced likelihood of
failure. However, unsustainably
high levels of RoE also indicate
higher risk. Some institutions may
have restrictions on their level of
profitability based on their
ownership structure so they should
not be disadvantaged by the
calculation method.
To avoid including one-off events
and avoid pro-cyclicality in
calculating contributions, an
average of at least 2 years should
be used.
(-)/(+)
Negative
values
indicate
higher risk.
However,
too high
values can
also indicate
high risk
GUIDELINES ON METHODS FOR CALCULATING CONTRIBUTIONS TO DGS
43
Core earnings
ratio
Where:
‘core earnings’ may be
calculated as (interest income +
fee and commission income +
other operating income) -
(interest expenses + fee and
commission expenses + other
operating expenses +
administrative expenses +
depreciation)
The core earnings ratio measures
an institution’s ability to generate
profits from its core business lines.
A business model which is able to
generate high and stable earnings
indicates reduced likelihood of
failure.
To avoid including one-off events
and avoid pro-cyclicality in
calculating contributions, an
average of at least 2 years should
be used.
(-)
A higher
value
indicates
lower risk
Cost-to-income
ratio
This ratio measures an institution’s
cost efficiency. An unusually high
ratio may indicate that the
institution’s costs are out of
control, especially if represented
by the fixed costs (i.e. higher risk).
A very low ratio may indicate that
operating costs are too low for the
institution to have the required
risk and control functions in place
(i.e. this also indicates higher risk).
(+)/(-)
Values of
the ratio
that are too
high
indicate
higher risk;
however
values that
are too low
may also
indicate
higher risk
Off-balance-
sheet liabilities /
Total assets
Large off-balance-sheet exposures
indicate that an institution’s
exposure to risk may be larger
than that reflected in their balance
sheet.
(+)
A higher
value
indicates
higher risk
GUIDELINES ON METHODS FOR CALCULATING CONTRIBUTIONS TO DGS
44
Qualitative
assessment of
the quality of
management
and internal
governance
arrangements
Depending on data availability
and operational capacity of the
DGS, the assessment of
qualitative aspects of its
member institutions may be
based on the following sources
of information:
-
questionnaires designed by
the DGSs to assess the
quality of management and
internal governance
arrangements of its
member institutions;
accompanied by on-site
and/or off-site inspections
performed by the DGSs;
-
comprehensive assessment
of institutions internal
governance reflected in the
SREP scores;
-
external ratings assigned to
all member institutions by a
recognised external credit
assessment institution.
Good quality management and
robust internal governance
practices may mitigate risks faced
by member institutions and reduce
the likelihood of failure.
Qualitative indicators are more
forward looking than accounting
ratios and they provide relevant
information on the institution’s
risk management and risk
mitigation techniques. In order to
be used in the calculation method
the qualitative indicators need to
be available for all member
institutions of the DGS. Moreover,
the DGS should strive to ensure
fair and objective treatment of its
member institutions and that the
qualitative assessment is based on
pre-defined criteria. The DGS
methodology for assessing the
quality of management and
internal governance arrangements
should include a list of criteria that
should be examined with regard to
each member institution.
(+)/(-)
Qualitative
judgment
can be both
positive and
negative
IPS membership
where the IPS is
separate from
the DGS
The IPS membership indicator
measures the level of ex-ante
funding of the IPS.
IPS membership, other things being
equal, should reduce the risk of the
institution’s failure because the
scheme insures the entire liability
side of the balance sheet for its
members. However, in order for
the IPS protection to be fully
recognised it should fulfil
additional conditions related to the
level of its ex-ante funding. This
indicative additional indicator
maybe further refined to reflect,
besides ex-ante funds, additional
available funding commitments
callable upon request and backed
(-)
Membership
in the IPS
with a
higher level
of ex-ante
funding
indicates
lower risk
GUIDELINES ON METHODS FOR CALCULATING CONTRIBUTIONS TO DGS
45
Systemic role in
an IPS scheme
officially
recognised as a
DGS
The indicator can have two
values:
(i)
the institution has a
systemic role in the IPS; or
(ii)
the institution does not
have a systemic role in the
IPS
The fact that an institution has a
systemic role in the IPS, for
example by providing other IPS
members with critical functions,
implies that its failure can have a
negative impact on the viability of
other IPS members. Therefore, the
systemic member of the IPS should
pay higher contributions to the
DGS in order to reflect the
additional risk it poses to the
system.
(+)
Only binary
values are
possible:
(i) indicates
higher risk;
(ii) does not
indicate
higher risk.
Low-risk sectors The indicator can have two
values:
(i)
the institution belongs to a
low-risk sector regulated
under national law; or
(ii)
the institution does not
belong to a low-risk sector
regulated under national
law
This indicator allows the calculation
method to reflect the fact that
some institutions belong to
low-risk sectors regulated under
national law. The rationale is that
such institutions should be
regarded as less risky for the
purpose of calculating
contributions to DGSs.
(-)
Only binary
values are
possible:
(i) indicates
lower risk;
(ii) indicates
average risk.
5. Potential losses for the DGS
Own funds and
eligible
liabilities held
by institution in
excess of MREL
Where:
‘own funds’ means the sum of
tier 1 and tier 2 capital in
accordance with the definition
in point (118) of Article 4(1) of
Regulation (EU) No 575/2013;
‘eligible liabilities’ are the sum
of liabilities referred to in point
(71) of Article 2(1) of the BRRD;
‘MREL’ means the minimum
requirement for own funds and
eligible liabilities as defined in
Article 45(1) of the BRRD.
This indicator measures the loss
absorbing capacity of the member
institution. The higher the loss
absorbing capacity of the
institution, the lower the potential
losses to the DGS.
(-)
A higher
value
indicates
lower risk
GUIDELINES ON METHODS FOR CALCULATING CONTRIBUTIONS TO DGS
46
Annex 4 - Steps to calculate annual contributions to the DGS
Upon collecting data from its member institutions, the DGS should take the following steps in
order to calculate annual contributions of all its members.
Step
Step description
Relevant provisions from
the guidelines
Step 1 Define the annual target level
Paragraph 37 of the guidelines
Step 2 Define the contribution rate (CR) applicable
to all member institutions in a given year
Paragraphs 39 of the guidelines
Step 3 Calculate values of all risk indicators
Paragraphs 48-77 of the guidelines
(requirements for indicators);
Annex 2 and Annex 3 (formulas for
indicators)
Step 4
Assign individual risk scores (IRSs) to all risk
indicators for each member institution
Paragraphs 1-5 and 13-17 of Annex 1
Step 5
Calculate the aggregate risk score (ARS) for
each institution by summing up all its IRSs
(using an arithmetic average)
Paragraphs 41, 54-56 of the guidelines
(requirements for weights of indicators);
Paragraphs 6-9 and 18 of Annex 1
Step 6
Assign an aggregate risk weight (ARW) to
each member institution (categorising the
institution into a risk class) based on its
ARS
Paragraphs 43-45 of the guidelines;
Paragraphs 10-12, 19-21 of Annex 1
Step 7
Calculate unadjusted risk-based
contributions for each member institution
by multiplying the contribution rate (CR) by
institution’s covered deposits (CD) and its
ARW
Paragraphs 35 of the guidelines
Step 8
Sum up the unadjusted risk-based
contributions of all member institutions
and determine the adjustment coefficient
(µ)
Paragraphs 44 of the guidelines
Step 9
Apply the adjustment coefficient (µ) to all
member institutions and calculate adjusted
risk-based contributions
Paragraphs 44 of the guidelines
GUIDELINES ON METHODS FOR CALCULATING CONTRIBUTIONS TO DGS
47
4.
Accompanying documents
4.1
Impact Assessment
Introduction
Article 13(3) of Directive 2014/49/EU requires the EBA to develop guidelines to specify methods
for calculating contributions to DGSs in accordance with paragraphs 1 and 2 of the same Article.
As per Article 16(2) of the EBA Regulation (Regulation (EU) No 1093/2010 of the European
Parliament and of the Council), any guidelines developed by the EBA shall be accompanied by an
analysis of ‘the potential related costs and benefits’. This analysis should provide the reader with
an overview of the findings as regards the problem identification, the options identified to
remove the problem and their potential impacts.
This annex therefore presents an Impact Assessment (IA) with cost-benefit analysis of the
provisions included in these guidelines.
Problem definition
Currently, in the majority of Member States the contributions of member institutions to DGSs are
not risk-adjusted, i.e. institutions pay their contributions to DGS as a fixed percentage of deposits.
It is reasonable to expect that the market is exposed to the following problems when the
contributions to the DGS are not risk-adjusted:
Competitive disadvantage for risk-averse institutions and unfair competition: risk-averse
members of the DGS can be worse off if they are pooled in the DGS with institutions with
high probability of default but their contributions are not differentiated according to the
risk profile. Where the contributions are homogenous, the member institutions with low-
risk profile subsidise the institutions with high-risk profile.
Moral hazard and insufficient incentives for sound risk management: in the absence of
risk-adjusted contributions the institutions may not have sufficient incentives to optimise
their risk level ex-ante. Institutions under the DGS scheme may take high risk and increase
their probability of default without bearing the marginal cost of additional risk, i.e.
increasing their contributions to the scheme. Overall, this practice could make the entire
banking system more vulnerable.
A second important issue that the guidelines aim to address is represented by variations across
Member States in the application of practices in the DGS which cannot be justified by structural
differences in national banking sectors, and may lead to:
GUIDELINES ON METHODS FOR CALCULATING CONTRIBUTIONS TO DGS
48
an uneven playing field where institutions of similar risk profile but located in different
Member States are subject to unequal treatment if the DGS contributions are based on
completely divergent calculation criteria.
Objectives
The guidelines firstly aim to establish a framework for calculating risk-based contributions to DGSs
that would be used in all Member States. This framework should be based on risk indicators
reflecting institutions’ risk-profile and ensuring a fair treatment of institutions in calculating DGS
contributions. In order to ensure there is objective risk assessment, the indicators should reflect a
sufficiently wide spectrum of aspects of institutions’ operations.
Secondly, the guidelines aim to ensure that the elements fundamental to the effective functioning
of the DGS contribution schemes are consistent across Member States. Table 1 summarises the
objectives of the guidelines.
Table 1 Objectives of the guidelines
Operational objectives
Specific objectives
General objectives
Ex-ante contributions to DGSs
are calculated as a function of
risk parameters.
Institutions fully internalise the
cost associated with risk-taking.
Reduce moral hazard and
promote fairness among
institutions in calculating DGS
contributions.
Common methods and criteria
are set for risk-based
contributions to DGSs.
Methods and criteria in the DGS
contributions framework are
consistent and comparable across
Member States.
Create a level playing field and
information symmetry across
Member States.
Baseline scenario
There are ten Member States
16
(DE, EL, FR, IT, LV, PL, PT, FI, NO
17
and SE) where DGSs apply
risk-based contributions
18
. In addition, some Member States (HU, RO) do not have a risk-based
contribution system in place but they make slightly different use of risk-based information in the
DGS framework. Therefore, in terms of transition to risk-based contributions, the guidelines are
expected to have an impact on the majority of Member States.
The remainder of the section will focus on the current practices in Member States in relation to
the technical options considered in the IA.
16
Member States throughout the IA refer to the Member States of the European Economic Area (EEA).
17
The system in Norway is based on RWA and covered deposits.
18
All data in this part of the IA is based on the following sources of information: European Commission, Joint Research
Centre Unit, ‘Risk-based contributions in EU Deposit Guarantee Schemes: current practices’, June 2008; Calculating
risk-based contributions for a DGS: Result of the EFDI Research Working group, June 2014; IADI General Guidance for
Developing Differential Premium Systems, October 2011.
GUIDELINES ON METHODS FOR CALCULATING CONTRIBUTIONS TO DGS
49
Categories, indicators and the weights of the indicators
Risk-based contributions are calculated on the basis of a single or several risk indicators (mostly
quantitative) that aim to reflect the risk profile of each institution. The indicators that DGSs use in
the calculation methods vary across Member States. While some Member States use single
indicators (FI, NO, PT, SE), other Member States use several indicators (AT, DE, EL, FR, IT, NL
19
).
Where multiple indicators are used, the number varies from 2 (EL) to 12 (DE
20
). Table 2 presents a
summary of the indicators used in Member States with risk-based contributions to DGSs.
Table 2 Indicators applied in Member States
Indicators
Member States
Capital indicators
DE, EL, FR, IT, NO, PT, SE
Liquidity indicators
DE, EL, FR, IT
Asset quality indicators
DE, IT
Income/profitability indicators
DE, IT
Qualitative indicators
DE, EL
Source: European Commission, Joint Research Centre Unit, ‘Risk-based contributions in EU Deposit Guarantee Schemes:
current practices’, June 2008; Calculating risk-based contributions for a DGS: Result of the EFDI Research Working
group, June 2014.
While the indicators used in Member States vary, the categories that the DGSs use are relatively
homogenous. Most DGSs in Member States focus on the CAMELS
21
approach. Accordingly, capital,
liquidity, asset quality and profitability ratios are the core quantitative components utilised in
most Member States. Qualitative elements are not used widely. Only two Member States (DE and
EL) use qualitative indicators in addition to quantitative indicators.
In terms of weights of the indicators, current practices can be classified under three categories,
including those which use: (i) differential weights determined by expert judgement and/or exact
calibration (DE, IT, NL); (ii) equal weights for all risk categories (FR); and (iii) only one risk indicator
with a weight of 100% (FI, PT, SE). For example, in Germany the methodology is based on
common statistical procedures, such as discriminate analysis, used in order to determine the
weights of the indicators. Table 3 indicates the risk categories/indicators with their respective
weights in the calculation of risk-based contributions in Member States.
Table 3 Weights for risk categories/indicators used in Member States
19
NL planned to introduce the risk-based contribution system in 2015. The system will include several indicators.
20
This is the statutory DGS for private banks.
21
C: capital adequacy, A: asset quality, M: management quality, E: earnings, L: liquidity, S: sensitivity to market risk.
GUIDELINES ON METHODS FOR CALCULATING CONTRIBUTIONS TO DGS
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