Einde inhoudsopgave
State aid to banks (IVOR nr. 109) 2018/11.5.1
11.5.1 Why is this a relevant characteristic?
mr. drs. R.E. van Lambalgen, datum 01-12-2017
- Datum
01-12-2017
- Auteur
mr. drs. R.E. van Lambalgen
- JCDI
JCDI:ADS590584:1
- Vakgebied(en)
Financieel recht / Europees financieel recht
Mededingingsrecht / EU-mededingingsrecht
Voetnoten
Voetnoten
See also Art. 79-87 CRD IV.
Cooperative Central Bank (CCB), SA.35334, 24 February 2014, para. 123.
EBS, C25/2010, 11 October 2010, para. 88.
Ethias, N256/2009, 20 May 2010, annex 1.1.
Alpha Bank, SA.34823, 9 July 2014, para. 6.
“De-risking” (i.e. a risk-reducing policy) can consist of a number of measures. A risk- reducing measure is a reclassification of a number of the bank’s ABS from the available for sale category into the held-to-maturity category, thus limiting the volatility of the negative revaluation reserve. ING, C10/2009, 18 November 2009, para. 52.
Banca Monte dei Paschi di Siena (MPS), SA.36175, 27 November 2013, para. 68-71.
Banks have to deal with several kinds of risks: credit risk, concentration risk, securitisation risk, market risk, operational risk, liquidity risk and risk of excessive leverage.1 Naturally, those risks have to be managed. Hence, risk management is very important in banking. The financial crisis showed that several banks had a weak and inadequate risk management. Consequently, those banks undertook to improve their risk management. This was welcomed by the Commission, because an improved risk management contributes to the return to viability. For instance, in one of its decisions, the Commission noted that the improvements of the bank’s risk management were “very important elements to restore viability and profitability”.2
To some extent, risk management is related to the corporate governance framework and the organisational structure. For instance, the introduction of a Chief Risk Officer (CRO)3 or the creation of a risk committee within the Board of Directors4 are both measures that can be categorised as corporate governance measures. Likewise, the commitment that the Risk Management department will be fully independent from commercial networks5 concerns the organizational structure of the bank.
It should be recalled that a reduction of the bank’s risk profile can be achieved in different ways.6 A bank can reduce liquidity risk by improving its funding model (“liquidity profile rebalancing”7). Furthermore, a bank can focus on its core activities and withdraw from risky activities. These risk-reducing measures will be discussed in sections 11.6 and 11.8. The present section will focus on risk management.