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3.4.3. Involvement of stakeholders in
the EBA’s work
Consultation with stakeholders in areas rele-
vant to the tasks of the EBA is being facilitated
and taking place through the Banking Stake-
holder Group (BSG). In particular, the group is
consulted on actions concerning regulatory
technical standards and implementing tech-
nical standards, and guidelines and recom-
mendations, to the extent that these do not
concern individual financial institutions. The
group may also submit opinions and advice
on any issue related to the tasks of the EBA,
with particular focus on common supervisory
culture, peer reviews of competent authorities
and assessment of market developments. The
BSG may also submit a request to the EBA, as
appropriate, to investigate the alleged breach
or non-application of Union law.
The track record of the BSG with regard to
providing their advice to the EBA is considered
to be very valuable and also timely. In 2012,
the BSG provided opinions, namely in rela-
tion to: own funds; disclosure for own funds;
credit valuation adjustment risk; specifica-
tion of the calculation of specific and general
credit risk adjustments; supervisory reporting
requirements for leverage ratio; supervisory
reporting requirements for liquidity coverage
and stable funding; prudent valuation; and
on capital requirements for CCPs. Further,
the BSG also provided its opinion on the Joint
Committee’s proposals on the draft regula-
tory technical standards for the calculation
methods under the financial conglomerates
directive (FICOD). Further, the BSG produced a
position paper ‘New bank liquidity rules: dan-
gers ahead’. Last but not least, the BSG has
provided its input through responding to EBA’s
public consultations as well as its informal
feedback and contributions to the EBA’s work
on technical standards and guidelines.
The EBA’s Banking Stakeholder Group is com-
posed of 30 members appointed to represent
in balanced proportions credit and investment
institutions operating in the Union, their em-
ployees’ representatives as well as consum-
ers, users of financial services and represent-
atives of small and medium-sized enterprises.
The EBA undertook a rigorous selection pro-
cess of the members of the BSG to ensure that
its composition is in line with the respective
requirements in the EBA regulation.
With the aim of streamlining the functioning
of the BSG, the BSG established four techni-
cal working groups on systemic issues, bank
capital, consumer protection and bank liquid-
ity. In 2012, the BSG held five regular meetings
and two joint meetings with the EBA’s Board
of Supervisors. Also some BSG members have
been actively involved in other activities of the
EBA, e.g. as speakers at the EBA Consumer
Protection Day in October 2012, and also as
presenters at the EBA’s research workshop in
November 2012.
The EBA has endeavoured to ensure full
transparency of the BSG’s activities. In this
context, the EBA website contains a specific
section on the BSG, which includes informa-
tion on the BSG members, its meeting dates
and minutes, membership of BSG technical
working groups, its rules of procedure, as well
as all the opinions the BSG has provided to
the EBA. Also, meeting dates and the list of
BSG members including their CVs have been
published online. The BSG currently envisages
producing a final report disclosing its activity
and achievements by the end of the term of
the current BSG (i.e. by September 2013 at the
With the aim to ensure that stakeholders out-
side the BSG are also appropriately informed
and engaged in the EBA’s work, the EBA has
established the practice of regular bilateral
meetings with representatives of some in-
dustry trade associations, consumers and
employees. In addition, the EBA, in line with
its obligation to follow due process, has or-
ganised open consultations on all its techni-
cal standards and guidelines that are being
drafted to ensure that input and comments
are gathered from all interested parties.