EU TLAC train rolls on
The weight of European banking regulator activism fell one more time on the industry late last week. The European Commission reported on "the completion of the Banking Union".The EC spelled out three reform themes:• swift agreement on an effective bridge-financing arrangement for the bank bailout fund, the SRF, and a goal of a common fiscal backstop "which should be fiscally neutral over the medium term, i.e. any use of taxpayers money would be subsequently reimbursed by the banks";• a legislative proposal for a European Deposit Insurance Scheme; and• a "parallel effort to further reduce risks in the banking sector and weaken the link between banks and their national sovereign".Stripped of jargon, the program means more capital, more bail-ins, more EU funding for a banking bailout fund, more work outs and more industry funding for bank recoveries. Next to no call on the public purse, and living wills in force for European banks.Michael Cunningham, a KPMG partner in Sydney, summed up the EU timeline.If capital changes "entered into force at the end of 2017 - which may be an ambitious target - this would allow the IFRS 9 phasing-in to begin from January 2018, and the TLAC provisions to be applied in line with the January 2019 timing set out by the Financial Stability Board, while all the other CRR2 revisions would apply from January 2020."Cunningham wrote of the package: "there are no major surprises for banks here on the substance of the proposed revisions, which will implement international standards agreed over the last two to three years."Larger credit institutions - especially global systemically important banks - will eventually face significantly higher capital, liquidity, reporting, and internal system and control requirements as a result of these proposed revisions, with the largest impacts likely to be from the market risk and TLAC requirements. "There is some comfort for banks with significant trading books. The date of implementation seems likely to be 2020 at the earliest, and there will then be a three-year period during which only 65 percent of the full market risk capital charge will be applied. "Thereafter, 'Basel 4' is expected to increase significantly the capital requirements on many European banks, as a result of both the new market risk framework and the prospective revised Basel Committee standards on credit risk (standardised and internal ratings-based approaches), operational risk and the capital floor."The EU-specific adjustments to some of the relevant Basel Committee standards - in particular the leverage ratio - will generally have a downward, albeit modest, impact on banks' capital requirements compared with the Basel Committee standards themselves."Meanwhile, the moves towards greater proportionality could reduce significantly some of the reporting, disclosure and additional capital requirement burdens on smaller credit institutions."