EBA published an overview of the findings from a review of the use, usefulness, and implementation of the Single Rulebook Questions and Answers (Q&A) tool. The Q&A tool provides common answers to stakeholder questions on the regulatory framework in EU. The review, which focused on the final Q&A for the Capital Requirements Regulation and Directive (CRR and CRD), was carried out in the second half of 2018, using questionnaires addressed to competent authorities and select industry representatives. Overall, competent authorities and institutions are satisfied with the utility of the Single Rulebook Q&A tool and the answers, but they made important and sometimes far-reaching suggestions for improvement.
The findings show that competent authorities and institutions widely encourage the use of the Q&A process and tool. The final answers are very largely followed and play a considerable role in the application and implementation of CRR and CRD. Similar rationales were given to explain the limited number of cases of non-application that were reported. EBA is considering these cases in more detail to better understand the obstacles and issues. Based on the observations made, EBA included in the report non-prescriptive good practice guidance that institutions could adopt when using the Q&A tool. The main observations of the review can be summarized as follows:
- Competent authorities use regular or ad hoc measures to encourage the use of the process and tool internally.
- Similarities were observed in terms of the measures taken by competent authorities at the institution level or by institutions internally to promote the Q&A tool and the use of answers.
- Cases of non-application of Q&A identified by survey participants were limited. Based on responses as of the end of September 2019, there were 29 cases out of about 620 final published CRR and CRD Q&A on policy issues.
- The number of cases of non-application notified by competent authorities was limited to 11 Q&A, while the number of such cases notified by institutions was 23 Q&A (with some duplication between the two).
- Competent authorities and institutions are, overall, satisfied with the utility of the Single Rulebook Q&A tool and the answers including the Interactive Single Rulebook, but they make important/far-reaching suggestions for improvement.
Based on the above observations, EBA put forward a non-prescriptive, good practice guidance that institutions could adopt with respect to the use of Q&A. The Q&A process was established by EBA in 2013 and followed a thorough due process involving close and ongoing interaction between EBA, competent authorities, and EC, with a view to developing common answers to stakeholder questions that are fully consistent with the EU legislative texts. Over 4,440 questions had been submitted through the Q&A tool at the end of 2018. Out of these, about 1,545 issues could be answered and nearly 1,360 questions had to be rejected. Notwithstanding some concerns about the time it takes to finalize answers, and in a very few cases about their impact, the feedback from the industry and the supervisory community has been broadly positive.
Keywords: Europe, EU, Banking, Single Rulebook, Interactive Single Rulebook, Q&A, CRR, CRD IV, Single Rulebook Review, EBA
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