38 Amendments of Udo BULLMANN related to 2010/2074(INI)
Amendment 18 #
Motion for a resolution
Recital D
Recital D
D. whereas at the G20unprecedented market and regulatory failures prompted the G20 to decide at its meetings in Pittsburgh it was decidedLondon and Pittsburgh to increase the quality of capital, to strengthen risk coverage, to mitigate pro-cyclicality, to discourage leverage and introduce a leverage ratio, and define liquidity standardto strengthen liquidity risk requirements as well as forward looking provisioning for credit losses,
Amendment 22 #
Motion for a resolution
Recital F
Recital F
F. whereas a "one size fits all" approach is detrimental to the European banking industry and consequently may harm economic growth and economic recovery, this means that a balance needs to be struck between a more standardized approach that is less susceptible to being arbitraged and a more customized approach that takes into account the diversity of the European banking sector,
Amendment 33 #
Motion for a resolution
Recital I
Recital I
I. whereas convergence between reporting for accounting purposes and, reporting for regulatory purposes is essentialand reporting for tax purposes is desirable in order to ensure that supervisors, tax authorities and investors are provided with the same transparent and clear information, and whereas dual reporting must be avoidedthough there may be a role for simultaneous multiple reporting frameworks to provide additional customized information,
Amendment 46 #
Motion for a resolution
Recital J a (new)
Recital J a (new)
Ja. whereas excessive maturity mismatches and an increasing overdependence on short term borrowing in the past decade was a significant contributor to the morphing of the crisis from a US subprime crisis into a global banking crisis; notwithstanding this, there has not been any relevant regulation to curb this excessive maturity mismatch in a meaningful way thus far,
Amendment 47 #
Motion for a resolution
Recital J b (new)
Recital J b (new)
Jb. whereas the excessive leverage and maturity mismatches were driven primarily by compensation maximising behaviour by bankers without any regard to the negative consequences on the real economy and tax payers; whereas there is a need for proposals that seriously curb risky practices including through imposing strict caps on bonuses at an absolute level and relative to base salary,
Amendment 48 #
Motion for a resolution
Recital J c (new)
Recital J c (new)
Jc. whereas the fact that the Basel II accord favours large banks over small, international banks over domestic ones and universal banks over simpler rivals is now well recognized and needs to be urgently addressed so as to stimulate more competition in the financial sector and penalize the systemic risk posed by large institutions,
Amendment 49 #
Motion for a resolution
Recital J d (new)
Recital J d (new)
Jd. whereas the indiscriminate application of Basel II and excessive uniformity of standards has led to a reduction in the natural diversity of the banking system and needs to be corrected,
Amendment 50 #
Motion for a resolution
Paragraph 1 a (new)
Paragraph 1 a (new)
1a. Welcomes the efforts made by the Basel Committee and the Commission; stresses however that new capital requirement rules should be drafted and implemented with care and their impacts should also be analysed in the wider regulatory overhaul framework;
Amendment 51 #
Motion for a resolution
Paragraph 2
Paragraph 2
2. Has concerns about structural deficits and imbalances in the current proposal, as well as the risk of harming economic recovery and economic growth; takes the view that, considering the current economic situation, it will be necessary to monitor that banks are not passing on the cost of the forthcoming proposal to end users of financial services;
Amendment 53 #
Motion for a resolution
Paragraph 2 a (new)
Paragraph 2 a (new)
2a. Stresses the need to reinforce the interaction between the supervisory review process (Pillar 2) and disclosure (Pillar 3) by making the results of stress tests and capital add-ons available to the public;
Amendment 56 #
Motion for a resolution
Paragraph 3
Paragraph 3
3. Recalls the important specificities of the European banking sector, such as the variety of business models operating under different legal forms and the fact that the corporate sector is predominantly financed through bank lending; calls therefore for a comprehensive examination of micro and macro-economic consequences entailed to the new proposed rules;
Amendment 58 #
Motion for a resolution
Paragraph 4
Paragraph 4
4. Urges the Basel Committee as well as the Commission to take proper account of such specificities, as well as; stresses the need to clearly differencestiate between investment and traditional retail banking services, commercial, cooperative and savings banks in the revised Basel II rules;
Amendment 62 #
Motion for a resolution
Paragraph 5
Paragraph 5
5. AskExpects the Commission to play an become more pro-active part in the process of reforming the Basel II rules, to promote and safeguard European interests, to coordinate the approaches of the Member States in order to achieve the best outcome for the European economy and to provide Parliament with regular reports on ongoing negotiations;
Amendment 67 #
Motion for a resolution
Paragraph 6
Paragraph 6
6. Acknowledges the importance of an international level playing field; points out, however, that that aim should not place the European economy and European industry at a competitive disadvantage; is convinced that the diversity of the banking sector should be reinforced rather than further harmed;
Amendment 73 #
Motion for a resolution
Paragraph 7
Paragraph 7
7. Stresses that the full commitment of all parties engaged in the Basel process to a clear and coherent implementation calendar is a precondition for successful reform, ensuring an international level playing field and avoiding regulatory arbitrage; calls on the Commission to strongly encourage all jurisdictions involved in the Basel process to implement agreed rules in a synchronised way;
Amendment 76 #
Motion for a resolution
Paragraph 8
Paragraph 8
8. Underlines that the implementation timetable must take account of the recovery process in Europe and reflect the overall impact of the revised standards on the industry and its capacity for lending to the real economy without excluding the possibility of grandfathering, phasing in or, if necessary, calendar revision;
Amendment 88 #
Motion for a resolution
Paragraph 12
Paragraph 12
12. Calls on the Commission for a proper assessment to be made of the impact on the real economy, with a special focus on SME financing before implementing new rules;
Amendment 97 #
Motion for a resolution
Paragraph 13
Paragraph 13
13. Calls on the Commission to create incentives for the banking sector to manage risk and profit with a view to long-term outcomes and to encourage banks to keep loans on their own books without excessive securitisation and to fully consolidate someall off-balance sheets witems like SPVhout exceptions;
Amendment 105 #
Motion for a resolution
Paragraph 14
Paragraph 14
14. Supports the initiative to increase the quality and level of capital in response to the crisis; recalls that this issue is intimately linked to accounting rules thus implying a consistent approach, having in mind as well global convergence;
Amendment 118 #
Motion for a resolution
Paragraph 16 a (new)
Paragraph 16 a (new)
16a. Urges the Commission to review the proposed eligibility criteria for core tier 1 capital and restrict the catalogue to those criteria which are necessary to ensure the quality of capital (i.e. permanence, loss absorbance, flexibility of payment);
Amendment 119 #
Motion for a resolution
Paragraph 16 b (new)
Paragraph 16 b (new)
16b. Stresses that the tax treatment of coupons and dividends is not relevant for defining the quality of capital; calls therefore on the Commission to abstain from additional eligibility criteria in relation to the tax treatment of hybrid instruments;
Amendment 134 #
Motion for a resolution
Paragraph 18 a (new)
Paragraph 18 a (new)
Amendment 150 #
Motion for a resolution
Paragraph 20
Paragraph 20
20. Is of the view that a "liquidity coverage ratio" should take greater account of the risk of concentration of eligible assets in any liquidity buffer, encourage diversification and discourage excessive concentration into one particular asset class; underlines that this ratio, when properly designed will improve institutions’ resilience to liquidity risk;
Amendment 164 #
Motion for a resolution
Paragraph 21
Paragraph 21
21. Calls, in the event of any structural liquidity standard being set, for a comprehensive impact assessment as well as for proper recognition of stable sources of funding specific to Europe (i.e. real- estate financing);
Amendment 168 #
Motion for a resolution
Paragraph 21 a (new)
Paragraph 21 a (new)
21a. Draws attention however to the likelihood that high quality liquid assets can become promptly illiquid in times of crisis and insists that such type of ratio should be integrated as a factor in stress tests together with a net stable funding requirement (NSFR);
Amendment 184 #
Motion for a resolution
Paragraph 25
Paragraph 25
25. Recognises the benefits of through-the- cycle provisioning (expected loss approach) as a possible additional measure to reduce pro-cyclicality and encourage recognition of expected credit losses with regard to the business cycle;
Amendment 189 #
Motion for a resolution
Paragraph 26 a (new)
Paragraph 26 a (new)
26a. Stresses the importance to introduce counter-cyclical capital requirements which would allow regulators to require banks to increase their minimum capital requirements in the view of the bank's individual exposure to emerging risks or to lower their minimum capital requirements during periods of prolonged lending and investment droughts or asset price deflation;
Amendment 190 #
Motion for a resolution
Paragraph 26 b (new)
Paragraph 26 b (new)
26b. Points out that counter-cyclical regulation requires harmonised criteria to ensure a comprehensive and careful monitoring of the financial markets and the market environment by supervisory authorities, including amongst others full exchange of information, synchronisation of regulatory actions as well as real time monitoring of exposures and risk including through a requirements for audit trails on all financial market transactions;
Amendment 193 #
Motion for a resolution
Paragraph 27
Paragraph 27
27. Notes the concept of a "‘crude"’ LR as a possiblvery useful, simple and hard to manipulate backstop against building excessive leverage, but has strong concerns about its added value of the kind that was built up before the crisis through the manipulation of complex Basel based capital requirements;
Amendment 202 #
Motion for a resolution
Paragraph 28
Paragraph 28
28. Is of the view that such a ratio, in order to be effective, must compriseinclude all off- balance sheet items and derivatives, must be clearly defined, simple and comparable internationally and should take into account the different leverage ratios existing internationally;
Amendment 211 #
Motion for a resolution
Paragraph 29
Paragraph 29
29. Is, however, concerned that a crude LR may penalise entities providing of the view that the maximum leverage cap should be low enough so it does not permit the excessive risk taking seen in the run up to the current crisis but high enough so as to not penalize traditional low-risk banking services (such as corporate and real-estate financing) or economies where the corporate sector is financed predominantly through lending;
Amendment 224 #
Motion for a resolution
Paragraph 30
Paragraph 30
30. Asks the Basel Committee and the Commission to explore alternativesupplements to a crude LR, such as setting backstop limits for business linanking activities and portfolios;
Amendment 230 #
Motion for a resolution
Paragraph 30 a (new)
Paragraph 30 a (new)
30a. Calls for an additional consideration of alternative forms of Leverage Ratio in Pillar 2; points out that a Leverage Ratio could for example have a flexible margin and supervisory authorities would have the discretion to act upon the breach of the limit;
Amendment 240 #
Motion for a resolution
Paragraph 32
Paragraph 32
32. Calls for enhanced standards as regards stress-tests, back-tests and addressing wrong-way risk as well as assessments of long-term social and environmental risks arising from companies and projects receiving bank loans;
Amendment 243 #
Motion for a resolution
Paragraph 32 a (new)
Paragraph 32 a (new)
32a. Calls for additional capital requirements for lending related to derivative instruments especially for OTC transactions;
Amendment 247 #
Motion for a resolution
Paragraph 33
Paragraph 33
33. Call for different capital treatment for an OTC transaction and a transaction through a central counterparty (CCP), provided that the CCP meets high-level requirements to be defined in European legislation while taking into account standards agreed at international level, with due regard for the potential costs for the corporate sector of using derivatives to hedge its commercial activities;
Amendment 254 #
Motion for a resolution
Paragraph 34
Paragraph 34
34. Underlines that the crisis has shown that interconnectedness between financial institutions is greater than interconnectedness between financial institutions and corporates, and takes the view that capital requirements for CCR should reflect that factbe more strict for exposures of financial institutions to other financial institutions and also reflect the dynamic nature of this risk over time; stresses that careful monitoring of the interconnectedness is necessary to detect a concentration of transactions between large players and to take subsequent regulatory measures regarding the CCR;
Amendment 256 #
Motion for a resolution
Paragraph 34 a (new)
Paragraph 34 a (new)
34a. Calls for the Commission to issue capital and liquidity standards, counter- cyclicality provisions and systemic risk penalties for the shadow banking system and other non bank channels for credit provision; considers that these regulations have to be, to the extent possible, equivalent to bank regulations;