11 May 2016
The EMF-ECBC expresses its views in an updated version of its July 2015 Paper on the BCBS’s proposed NSFR Standard, which it has today submitted to the European Commission and the European Banking Authority (EBA). The Paper has been updated notably to take account of the recommendations of the EBA in its December 2015 Report on the NSFR.
In its latest Paper, the EMF-ECBC recalls that covered bonds played a pivotal role in bank wholesale funding during the recent financial turmoil as one of the only asset classes able to restore investor confidence and ensure access to debt capital markets for European issuers.
With this in mind, the EMF-ECBC advocates in particular the setting of Required Stable Funding (RSF) and Available Stable Funding (ASF) to zero for interdependent assets and liabilities, including all situations where a matching principle exists in law.
In structures where there are no interdependent assets and liabilities, the EMF-ECBC highlights:
(i) the potential for derogation from the NSFR on an individual institution basis where the institution is part of a group/sub group;
(ii) the adjustment upwards of ASF factors for covered bonds with a residual maturity of less than one year;
(iii) the need for identical treatment of mortgages in terms of RSF weighting, regardless of whether they are funded through covered bonds or not; and
(iv) the recognition of the secured nature of the asset in the assignment of RSF factors to swap agreements on covered bonds.
Finally, from an investor perspective, the EMF-ECBC welcomes the fact that extremely high liquidity and quality as well as high liquidity and quality covered bonds are assigned RSF factors in line with their categorisation under the European Commission’s Delegated Act on the Liquidity Coverage Requirement1 . However, the EMF-ECBC asserts that covered bonds backed by cover pools with high credit quality should not be treated differently in the NSFR because of differences in issue size so as to ensure that covered bonds issued from the same prime cover pools fulfil the same stable funding requirements.
In commenting on the EU implementation of the BCBS NSFR Standard, Luca Bertalot, EMF-ECBC Secretary General, stated:
“The tailored and proportionate EU implementation of the Basel III framework is vital for the viability of the mortgage and covered bond industries, all the more so in light of the advent of yet more regulatory change in the form of “Basel IV”. Appropriate liquidity and capital requirements will be determinant for the role the Industry can play in supporting not only growth, but also in meeting the EU’s energy targets.”