Bezpieczny Bank

Marcin Borsuk
Assistant Professor at the University of Gdańsk and Senior Economist at National Bank of Poland

Andrzej Dżuryk
PhD programme graduate at the University of Gdańsk and Corporate and Investment Banking Director at Société Générale in Poland

Position of the European Financial Congress on the Supplementary Supervision of Financial Conglomerates

Abstract

This article presents the position of the European Financial Congress in relation to the European Commission’s consultation document on the supplementary supervision of credit institutions, insurance undertakings and investment firms in a financial conglomerate. From 9th June till 20th September 2016, the EC ran a public consultation on the evaluation of the financial conglomerate directive (FICOD), whether it delivers on its objective to identify and manage group risks, i.e. multiple gearing, excessive leveraging of capital, contagion, complexity management, concentration and conflict of interest. Financial conglomerates were originally represented by bancassurance. Over time financial institutions have expanded into investment banking, asset management and other financial activities, with separate segment supervisions. Now, they are getting bigger, more complex and international, expanding into the real economy, outsourcing critical processes to non-regulated external offshore companies. Moreover, manufacturing companies are developing competencies in banking area and traditional financial institutions are being challenged by expanding fintech projects. The evaluation of supplementary supervision shall lead to better regulation in terms of relevance, effectiveness, efficiency, coherence and added value. As a result, the legislation shall contribute to enhanced financial stability, safeguard creditors’ and policyholders’ interests, and promote the competitiveness of financial conglomerates within the EU and at international level. From the Polish perspective, FICOD shall protect the financial system from the import of group risks and lead to secure growth of local financial conglomerates, enjoying a level playing field in the EU. The EC consultation paper was addressed by representatives of different groups of stakeholders in the Polish financial market, including in particular: universal banks, auto loan companies, insurance undertakings, regulatory bodies, consulting firms and academia.

Key words: financial conglomerates, financial conglomerate risk management, group risk management, financial conglomerates supervision, FICOD, financial stability