Deutsche Bank
The comments of Deutsche Bank focus on the following areas:
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Acknowledgement that there are many methods for assessing a risk culture and providing firms and supervisors flexibility to apply these as appropriate;
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Enhancing the principles-based approach to address points where the guidance risks advocating a “tick box” approach to track risk culture information;
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Ensuring that the guidance is a tool to drive continuous improvement on risk culture and enhanced dialogue between supervisors, boards and senior management; and
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Clarifying the role of the Board and the distinction between their responsibility to set the risk culture framework and that of senior management to embed and deliver it.
Full Deutsche Bank comment
Insurance Europe
Insurance Europe agrees that the right combination of staff at the supervisors with a high level of knowledge and seniority is important to be able to challenge the undertakings board and senior management. However, ensuring seniority at the supervisor can be quite a challenge, since in the majority of the EU supervisory authorities are a public undertaking under public rules which have limited resources. Hence, it may prove very challenging to guarantee that staff with the level of seniority the guidance seems to aim at is available on a national level.
Full Insurance Europe comment
US Chamber of Commerce
If the FSB continues to believe that SIFIs should be subject to the double checking envisioned in the Risk Culture paper, then the FSB and regulators need to take into account differing business models and situations to ensure that risk management systems fit the needs and characteristics of a specific SIFI rather than meet preconceived notions of how a risk management system should be constructed.
Otherwise the Risk Culture paper and the Proposed Risk Appetite Framework can act as a driver towards a homogenous risk management system for SIFIs, which will do more harm than good by reducing the benefits of risk diversification. By forcing financial institutions to have a one size fits all approach to risk management, the Risk Culture and Risk Appetite Frameworks may concentrate risk by eliminating flexibility and managerial initiative.
Full US Chamber of Commerce comment
List of responses
Original consultation, 18.11.13
© FSB - Financial Stability Board
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