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CP10 (Full Document) - European Banking Authority

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IRB approach can be given only if the competent authority is<br />

satisfied that the institution's systems for managing and rating credit<br />

risk exposures are sound, are implemented with integrity, and meet<br />

the requirements listed in Article 84 and Annex VII, Part 4 of the<br />

CRD. Approval to use the AMA approach can be given only if the<br />

competent authority is satisfied that the institution’s systems for<br />

measuring operational risk meet the qualifying criteria in Annex X,<br />

Part 3 of the CRD.<br />

13. One of the greatest challenges for supervisors in implementing the<br />

CRD is defining the conditions under which they will be satisfied with<br />

these systems. Ideally, the conditions should be convergent across<br />

EU member states, in order to make the playing field as level as<br />

possible for institutions using the AMA and IRB approaches.<br />

14. CEBS has chosen to publish these guidelines for consultation while<br />

the <strong>European</strong> institutions are still debating the CRD’s final form and<br />

details. Since some of the CRD’s provisions might be substantially<br />

revised before the Directive comes into force, this strategy carries<br />

the risk that some of the guidance presented in this paper will<br />

become obsolete. However, the technical details of the CRD are<br />

unlikely to change. Moreover, given the short remaining timeframe<br />

for national implementation, any further delay in consultation may<br />

make it impossible for CEBS to influence national implementation,<br />

which is one of CEBS’s key tasks. CEBS’s goal is to reduce<br />

inconsistency in implementation and supervisory practices that are<br />

within the competence of the supervisory authorities, while<br />

respecting the need for flexibility and supervisory judgement and<br />

respecting national diversity. By promoting a consistent approach to<br />

supervision across the EU, and by promulgating best practices in<br />

banking supervision and risk management, CEBS will contribute to<br />

enhancing the effectiveness and efficiency of bank supervision,<br />

ensuring a level playing field, and promoting the competitive<br />

standing of the EU banking sector. The new capital regime offers an<br />

unprecedented opportunity to make progress in these areas, because<br />

it implies a new approach to supervision for all EU supervisory<br />

authorities.<br />

1.2. What is covered and what is not?<br />

15. Since the guidelines are supposed to support the national<br />

supervisors’ work when dealing with a model application they cover a<br />

considerable range of topics, sometimes with a considerable degree<br />

of detail, concerning the application, decision and especially the<br />

assessment process.<br />

16. The guidelines relate primarily to the AMA and IRB Approaches. They<br />

do not provide any guidance on the Standardised Approach for Credit<br />

Risk. They do, however, provide some guidance on the Basic<br />

Indicator Approach and The Standardised Approaches for operational<br />

risk.<br />

Page 7 of 123

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