Today, the European Central Bank (ECB) published the results of its Supervisory Review and Evaluation Process (SREP) for 2022.
?The SREP is an annual exercise in which supervisors examine banks’ risks and produce capital requirements and guidance for each individual bank (which is in addition to legally required minimum capital). It assesses four main elements: the viability and sustainability of business models, the adequacy of internal governance and risk management, risks to capital and risks to liquidity and funding.
Below the most important aspects are summarized. For more information, please contact our legal regulatory experts at
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- ?SREP scores remained broadly the same overall - In 2022 92% of institutions received the same overall SREP score as in 2021 while 4% saw their scores worsen.
- ?Overall, significant banks continue to maintain solid capital and liquidity positions. Their average Common Equity Tier 1 (CET1) ratio remained slightly below 15%, only marginally lower than the year before. Liquidity coverage ratios continued to be high, at 162% on average, thanks in part to the targeted longer-term refinancing operations (TLTROs) and other central bank support measures.
- A marginal improvement was observed thanks to better key risk indicators, such as non-performing loans (NPLs) while, in the light of the prevailing uncertainty, the overall assessment was conservative. The overall capital requirements and guidance increased to 15% of risk-weighted assets (RWA) on average after 14.7% of RWA in the 2021 SREP cycle. Banks identified as significant institutions maintain solid capital and liquidity positions, with the vast majority going beyond the levels dictated by capital requirements and guidance.
- ?Qualitative measures were issued primarily in the areas of credit risk and internal governance, where supervisors looked at the broader quality of banks’ internal risk control frameworks and the effectiveness of banks’ management bodies. Even though their number is falling, measures to mitigate internal governance and risk management-related deficiencies have been imposed on 76% of significant institutions, which represents the highest percentage across all types of measures. Overall, the deficiencies identified in the assessment of governance and risk management mainly relate to the management body, risk management framework, internal audit function, compliance function, risk data aggregation and reporting.
- ?A specific capital add-on was included in the P2R decision for a few institutions with very high exposure to the risks from leveraged transactions or highly deficient risk controls in this line of business.
- ?Given that no SSM-wide capital stress test was performed in 2022, Pillar 2 guidance (P2G) remains largely unchanged compared with 2021, at 1.3%.
- ?The 2022 SREP cycle resulted in NPE P2R add-ons for 24 significant institutions where a shortfall was identified relative to the ECB’s coverage expectations, as the cover for risks arising from aged non-performing exposures (NPEs) was assessed to be inadequate.
- ?ECB Banking Supervision has launched several digitalisation-related initiatives across the banking sector with a view to monitoring the healthy adoption of digital transformation that makes business models more robust. The outcome of these initiatives will inform the supervisory assessment in the next SREP cycle
- Outsourcing becomes really important, the way banks outsource critical functions will be important for the continuity of services.
- SREP and crypto exposure – The EU banks’ exposures was limited. The size and number of these exposures remain pretty contained. Consequences of the crypto winter of 2022 were nihil. Now with the BCBS guidance, approved in December, the SSM expects a quite strict and robust set of rules guiding the exposure of banks to these sectors.
- Use of internal models by banks - ECB has reviewed banks internal models through TRIM, and keeps follow up with onsite inspections. There is not a generalized dissatisfaction, there are issues with individuals banks, that need to be fixed from time to time Some banks have internal models that cover very small portfolio, and the amount of attention that needs to be given to them is disproportionate – SSM has launched an initiative to simplify the IM landscape . Not saying ECB inspectors to hammer banks using IM.
- Counterparty credit risk – The SSM got nervous when commodity started seeing volatility because of exposures of EU banks, notably with specific transactions dealing with private equity, hedge funds dealing with leverage buy outs – risk management of banks need to be in the right place.