 So welcome. Good morning. Welcome to Frankfurt on, again, a rainy and gray day to the public hearing in the context of the consultation on the approach for the recognition of institutional protection schemes. We will start this morning with a short presentation, and then we are at your disposal for questions. With me here on the podium is Jukka Vassala, Director General of DGMS3, and Esther W. Meyer, Principal Supervisor in the same Director-General. So I think without further ado, we go into the presentation, and we are then looking forward to your questions. Thank you very much, Wolf, and good morning also from my behalf, and welcome to this event. This is part of our public consultation on our IPS criteria, and we started this consultation, first of all, because it is a good practice to be transparent on important policy issues, and then this issue is very relevant for some parts of the banking sector, and I think the people who are here are the ones who are mostly interested in this topic. So starting with the description of the IPS, this is, of course, well known to you. IPS, what is the object of our criteria, is a contractual arrangement, which is intended to protect member institutions, in case of liquidity and solvency problems, and it's intended, as also stated in the regulation, to avoid a bankruptcy of a single institution that is a member of this arrangement. So it's a sort of solidarity mechanism across the institutions, and it's important to note that it's not a consolidated banking group, so the banks that are part of an IPS are not subject to consolidated supervision, and they are not treated in the same way as groups that are subject to consolidation, which can be in many ways regarded as a single entity from a supervisory perspective. So these are the groups that have been established under the Article 10 of the CRR. So the members of the IPS are still autonomous institutions, and they are supervised on an individual basis. And then what is especially relevant from the ECB perspective and the reason why we took particular interest in this topic is that in this IPS that are currently there, we typically have both significant and less significant institutions. And then also you can have these consolidated groups that are also IPS. So there is a possibility of being both a consolidated group and an IPS. And we don't have many cases where the IPS is just consisting of less significant institutions, but typically there are both significant and less significant institutions. And especially relevant, the IPS are for cooperative banks and savings banks. What is the relationship between IPS and the deposit guarantee sheems? This is an important point to note as well. We can have cases that the IPS is recognized as the deposit guarantee system and then provides the protection of deposits. But the IPS doesn't have to be the deposit guarantee system as well. This is a possibility that is there for countries to organize deposit guarantee according to the requirements of the deposit guarantee directive. We are not in the ECB responsible for the supervision of the deposit guarantee systems. For instance, we are not responsible for recognizing whether the deposit guarantee systems are adequate. Our responsibilities relate to the IPS and the institutions that are part of the IPS. There are some duties for supervisors regarding deposit guarantee systems, but it's not the competence for recognizing these systems as delivering a sufficient deposit guarantee. And then there is also the issue that if an IPS is also a deposit guarantee system, the funds need to be also, of course, available for deposit guarantee, which is at minimum 0.8% of the covered deposits that need to be existing in the Exante funds. And this can then limit the funds that are available for solvency support purposes if the IPS is also a deposit guarantee system. So this is one aspect that we, of course, need to take into account. Regarding the regulation of IPS, and this is the core issue for us regarding our approach to IPS, there is on one side this beneficial system that protects the solvency and liquidity of individual institutions and is reducing significantly the risk of failure at the level of individual institutions. So this is clearly a benefit coming from an IPS system. But then on the other side, these IPS can also have regulatory benefits, which are quite significant. So in a way, if there is an IPS that is credible in producing this support, then we can have these regulatory benefits. And the regulatory benefits can be obtained if the IPS meets the certain conditions that are listed in the CRR. And then what we have done is that we have considered then how we actually supervise that these conditions are met. And we have developed some additional practical criteria for that, which is now also subject to consultation. So what these regulatory benefits are, if an IPS is recognized, then there is a zero risk weight for exposures across the IPS members, and there are no large exposure limits. So these are quite significant benefits. And then there can be further waivers if IPS is meeting these criteria. There can be waivers from liquidity requirements, which then allow, in a way, liquidity supervision at the level of the whole system. The IPS, currently what we have, can be found in three countries, Austria, Germany, and Spain. But if we look at the total number of credit institutions in the SSM, we have actually 50% of the total number covered by IPS. So in that sense, this is a highly significant issue. And then in terms of assets, we are covering roughly 10%, so also very significant parts. In Austria, we have eight IPS with 370 member institutions in Germany, only two, but big ones with 1,465 member institutions, also in the cooperative and savings bank sector. And then we have in Spain two IPS, which one of them, Casamaris, a significant institution. And then Solvencia is less significant than these are also then consolidated groups. And then we have also credit unions in Spain with an IPS. If I go more into the substance of the work that we have been carrying out for more than a year now, something like one and a half years, we started with the stocktake of the IPS that are there. We looked at the tasks of the IPS centers, how the governance risk monitoring is organized. We looked at the development of ex-ante funds for solvency, support purposes, et cetera. And then after that, also having a lot of discussions with the national authorities and with these existing IPS themselves, we started developing these criteria. And the main objective is that we should have a common approach for supervisor purposes across the SSM in order to have a consistent approach. And in particular, if there would be new applications for having an IPS, then we would have this consistent and common approach how to address these applications. And then also for the existing IPS, there has to be a regular monitoring, at least an annual monitoring, which also contains a check whether the IPS continues to meet these criteria and then also how the risk monitoring of individual members is conducted in the IPS. We are not challenging the previous decisions by national authorities when they recognize the IPS and then allow these regulatory benefits. And that's not the purpose. We are, in a way, now starting this assessment work. And the objective is not really to start by challenging these previous decisions, but to understand even better the IPS and then see if there are some areas where improvements would be needed in the way that the IPS function. The fact that we have both significant and less significant institutions typically in this IPS creates a need for us to have a very well-defined process. How do we cooperate with the national authorities, which are responsible for the direct supervision of the LS size, and then ECB, which is responsible for the direct supervision of the S size, in the case that there has to be a decision made regarding this IPS. And the idea is that these decisions would be made in a fully coordinated and consistent ways, or if there is, for instance, a new application for an IPS that covers both significant and less significant institutions. This would be done in a coordinated fashion with the national authorities. And then secondly, this monitoring, the at least annual monitoring, which is required, we have to establish joint monitoring together with the NCAs. And this is already quite well underway. And from an IPS perspective, we would like to have a single contact point for each of the IPS that is subject to this monitoring. And this will then facilitate our interaction with the IPS, which will then be simultaneous together with the ECB and NCAs so that we don't have a separate communication with the IPS from the NCAs and from the ECB, but it should be always joint and well coordinated. Regarding the criteria for the IPS assessment, the first key issue is that the IPS needs to be able to provide sufficient support and in a timely manner to a member that faces the solvency or liquidity problems. And we say that there should be a clear commitment to provide support when necessary, and that there should be a clearly defined process on how these support actions would be taken, and that there should be a clear governance, and this is making structure, which would allow them timely decisions. And then there should be a financial capacity as well in terms of funds readily available, and there should be an extant fund available for these support purposes. There might be some conditions that are linked to the support operations, such as changes in the management, for instance, which can be useful to avoid or limit the moral hazard problems. Regarding the commitment to support, first of all, we have made clear that it doesn't have to be always a financial support, but it can be also some other measures, some other measures like mergers, risk limits, divesting risk positions, or something else that can be taken to correct the problem. So it doesn't have to be necessarily capital injection or liquidity provision, and the intervention would be expected, at least when it is seen that there is no means for the individual bank privately to fix the issue. And regarding Pillar 1 requirements, we see that there should be a clear commitment to maintain the bank above Pillar 1 requirements, and if the bank has a Pillar 2 requirement, additionally, there should be a timeline that is set by the supervisor to meet that requirement, and then we would expect the IPS to intervene if this timeline cannot be met. The second main area is that the IPS needs to be able to identify at an early stage financial problems of an individual member and therefore be able to take also early and preventive actions, and it is needed that the IPS has a clear methodology for risk measurement that is applied to individual IPS members, and there should be a regular monitoring of the individual members and sort of classification of the riskiness of the institutions. That means that the IPS members should be providing information at the regular intervals to the IPS center in order to conduct this monitoring on a regular basis. And we also consider that there should be some possibility for the IPS to influence the risk situation and risk management at the level of the individual institutions, and that the IPS members are informed about problems if those are detected by the center. That is the basic content of the criteria. I'm not going now into further detail regarding those criteria. We are now quite well underway in this public consultation. We are having now the public hearing, and then 15th of April there is the ending of this consultation. And you are still, of course, able to provide comments to us in writing until that time. And then after that, we will be finalizing this work, and the plan is that this IPS criteria that have been consulted and we have incorporated the feedback will be issued as a part of the ECB guide on options and discussions. This is the bigger project that has been going on, covering many options where the ECB has been developing and has already decided a common position how those options should be applied in the SSM. And the timing is such that we are planning to issue the amended options and national discretion guide, which has also been consulted with the industry in summer 2016. So this is a bit vague concept because there are many definitions of summer. For me, summer is from June to August, but the Mediterranean people, the summer is from August to September. So this gives quite a lot of flexibility. So it should be before October, I think. That's the. OK, I think I would leave it to here. And as Wolf said, we are here to answer your questions. OK, and we have microphones in the room. And please let us know who you are and what your organization is. It's switched on already. Thank you. You have it found Austrian savings banks representing IPS, of course. Two questions for clarification. Basically, you were mentioning on the second slide the link between IPS and DGS. When it comes to the fund, do we see the possibility that one fund covers both objectives, the objective of the DGS and also the objective of the IPS? Because of the end of the day, both measures, meaning support of IPS members and also protection of deposits are covered by this ex-ante fund, which means if I save, if I support one member, that means at the end of the day, also the deposits of that relevant bank are covered and safe. The second question would be on you mentioned, you are thinking of coming up with improvements. In which direction are you heading in this regard? Are you thinking of improvements when it comes to supervisory process? Or are you thinking on level one text as well? Thank you. Thank you very much for the first question. It is possible, but then of course, we need to be clear on the different purposes of the funds so that the DGS funding requirement has to be always met. And then in a way, then the funds available for the solvency support can be limited. Or you cannot deploy the fund for solvency purposes such that the DGS protection or deposit protection is jeopardized. Because typically, the case for the solvency support comes before you have to pay to the depositors, which is then later on typically in the process if the bank goes to resolution or liquidation at the end. If the IPS for some reason is not managing to solve the situation, which of course it's expected that the IPS would be able to solve. But there has to be the funding available for deposit support purposes as well. Regarding the improvements, I mean, we are now only starting with this new supervisory process. During the spring, we will start with the so-called monitoring groups where we have both the ECB and the NCAA representatives that then will be organized for one IPS. And these groups will start looking together more in detail the IPS. The information that is available. And then see also how the risk monitoring is organized in these IPS systems. And then there can be some, as always, when supervisors look at something, there can be some recommendations or some requirements to improve in the IPS. But we are quite early now. It's very difficult to say because we haven't started this work, what kind of feedback then would be given. We also need to collect some information at the level of the IPS. The IPS has to produce the aggregated balance sheet, the aggregated capital calculation, and then information, of course, to the supervisor to see how the risk monitoring in the IPS work work. But we haven't yet received this information. And this will be the work for this year. For Kegelman European Association of Corporative Banks, I would just also like, after these questions, related to the DGS, raise two questions or proposals. I mean, we saw now that you mentioned DGS in the slide. Unfortunately, there is no reference at all in the paper itself. But there is this mechanism regarding what was just discussed to keep a minimum amount of funds in the DGS if you apply alternative measures. So that would also possibly quite nice to establish a reference to see how these mechanisms work together. The other point is that you expect stress tests to be done by the IPS, but also the DGS have to do stress tests and also the stress tests for the DGS include alternative measures. So it would also possibly quite nice to, if you could, clarify how these two things, at least in the paper, possibly not today, how these things work together then. Thank you. Yes, this is an important issue. We didn't cover the DGS in the document because DGS supervision is not the responsibility for the SSM directly. But of course, there is a link to DGS which has to be taken into account. And there should be cooperation in the future to avoid any duplicated requests. But this will, as you say, this is a work for future. And we will then see in practice how this will be carried out. But yes, it's not covered in the document. Thank you. Martin Suteski with the German Savings Banks. First of all, let me say that we appreciate very much that the ECB acknowledges the importance of IPS with the proposed guide. And even though they are only known in three countries of the SSM, they do represent, as you pointed out, 50% of all banks in the SSM. Now I have a couple of remarks that I would like to make. And the first remark also relates to the DGS topic that was just addressed. We would like to suggest to have a very close look and to ensure that the IPS guide will be compatible with the DGS regulation, i.e. the DGS directive and the EBA guidelines that relate to the DGS. Contribution calculation, for example, or stress testing, all of these topics. And we have an inclination that there could be room for a conflict between the limit of 100,000 euros, deposit protection, and the broader scope of the failure protection of an IPS. Now my other remarks relate to an issue that has been discussed very often with regard to IPSs, model hazard, where obviously the question is whether an IPS that is sort of insufficiently designed would create adverse incentives for free riders within the IPS. And because of that problem, of course, it's very important to have measures in place to prevent that. And we think that there are two very crucial measures that are very important that they are also reflected in the guide, thankfully, and that's very much appreciated. The first one is proactivity, where we think that risk management needs to be in place to detect problems very early in the process and to intervene and to have different steps of intervention at hand. However, we think that the current wording in the guide may also be read as that members of an IPS need to have uniform risk management standards. Now, of course, there needs to be comparability. That's true. But we think, and that's, of course, the regulatory framework as well, that the managers of a bank and the board ultimately is responsible for a proper risk management. So considering that IPS members are autonomous banks and institutions, we would suggest to reword the guide in that regard as to not make that implication. The other measure that I think is very important to prevent moral hazard is to have individual case rulings in an IPS. If you have direct claims in an IPS, you always risk a situation where the IPS may be regarded as an insurance, as an insurance-type protection. And so to avoid that, we think that there need to be individual case rulings. And we think that the consultation paper, which currently very strongly suggests an automated mechanism, should also be amended in that regard and that relates to 137B. Thank you very much. Well, thank you very much for these remarks, which probably you will also submit during the consultation. So we will certainly take a look at these comments very carefully. I mean, the relationship with the DGS was already mentioned by the previous speaker. I think this is really a sort of next stage question where we'll then see how in practice the different IPS, that might be also DGS function. We are not developing the criteria regarding the DGS function, as I mentioned. It's outside the scope of our work. But there has to be, of course, due regard and cooperation with the responsible authorities on the DGS side. The moral hazard issue, I mean, we have recognized that, well, we can, of course, take a look at the different wordings. I must say that in the preparation of the criteria, we spent really a lot of time in finding very balanced approach. But of course, it doesn't mean that it cannot be improved. We came up with this in after a long deliberation. We came up with this wording of there should be clear commitment. There should be sufficient funding. There's a clear expectation. But we are avoiding sort of automatism in those expressions. Regarding the comment that we demand uniform risk management, I don't think that's the case. But we, of course, need to have consistency so that the individual members of the IPS can be monitored. And also, there can be confidence that the risks are managed well at the level of the individual banks. I don't know if you want to add something, Esther? I think you already summarized this quite well. So the idea is not to impose something very detailed on all institutions, but really to ensure, first of all, that the risks are managed properly in the individual institutions. And also that the IPS has the possibility to have really a clear view on the situation of the banks. And therefore, you need to have some comparability in the data. And also the point that the support can maybe and should come with the conditions can be important to limit the moral hazard. So there should be also consequences to the individual institutions if they need to resort to IPS supports. Pierre Bednarski, PWC. I'm very glad to be invited here to this hearing. I like very much the paper. I would like just to share a few observations. I think one aspect has been already taken on the board, which is the relation to DGS, but also I would add relation to resolution, because I understand this paper assumes as a fundamental principle that the last line of defense will be resolution, right? And the resolution techniques resolution fund is available. So I understand that we don't assume that the IPS will be the final say in terms of the rescuing the bank, though there is another line. So I understand that there is an underlying assumption that the funds should be available. The funds should support liquidity and solvency of the problem banks in the IPS. But there might be a case that the institution is no longer viable. It's not economically viable. It should be either, let's say, divided into bet and good bank sold with application all these resolution rules and techniques. So I understand that this perhaps could be clarified that the IPS is not Panacea for everything. It has some limitations. The second issue is proportionality. I see a little bit too little of proportionality here. And this refers also to the question of having uniform risk management system. I think this could be read between lines that there is an expectation of that nature in this document. So I would stress more proportionality and says that the small banks do not need to have such robust systems like, let's say, central bank right or whatever. So that's the second one. The third one is the question is to what extent you would look at this availability of funds in terms of having unlimited right of the central institution to draw on funds from single institutions, small cooperative banks or saving banks. Because this could be dangerous, in fact, because IPS is cannot endanger a single member, right? I understand that you would acknowledge that there should be also some provisions saying that the contribution, especially extraordinary ad hoc special contributions when the pot is empty, that this kind of contributions cannot go above the financial possibility of single members. And I think there are, for example, I look into RIFIs and prospectus issuing subordinated debt international markets. And they clearly say the contribution, 50% of earnings for three years period, and the maximum extra contribution is 25% of surplus-owned funds over the regulatory threshold. I understand this document assumes this kind of backstop measure, so you cannot draw too much on the single institution because it might endanger the single institution. I understand this is underlying a assumption. Please confirm. And the last point is there is the reference to Article 113, Paragraph 6, when there is this requirement that there shouldn't be any legal or practical impediment in regarding flow of owned funds in the group. And I would appreciate if you could clarify, because even the wording of the CRR in that respect is not fully clear. What do you mean exactly? And how you would access this criterion? Thank you. Thank you very much. The link to resolution, it's true that it's not covered also in the document, but the resolution arrangements are there, of course, existing for also bags that part of IPS, but they have to be, according to the BRD, they have to be the resolution tests that the criteria for resolution are met, such as the public interest criteria and the other criteria. And there is also, of course, the possibility of liquidations of the resolution is not an automatic possibility. The proportionality issue, I mean, we will go through the guideline very carefully regarding this comment that it delivers the correct message on what is expected from the individual bank level risk management. And I fully agree that if you have IPS with significant institutions, that can be very large and complex. It's a different type of risk management that is required from the primary banks. Regarding the availability of funds, we noted that in a way that if there is a cap to the individual bank contributions, it should not be a sort of fixed or irrevocable in the sense that if there's a need that might have to be exceeded. And there is also a commission view that each bank shall be obliged to provide the institutional protections with the funds that are necessary to protect its members. But of course, as you say, the stability of the IPS itself or the individual other members has to be considered. So this is not to be jeopardized, of course. But I mean, this is an area where we cannot say that if there is an original cap established, that there might cannot be any conditions where additional funds might be needed. I leave the last question on regulation to Esther. So you're right, diverting in CRR is quite difficult to understand in this regard and also to have this link for IPS that are not consolidated banking groups and that normally also have limited investments in owned funds in the group. But I mean, it is a requirement. We would use the similar specifications that were prepared for Article 7 that also includes this condition that there should be no practical and legal impediments. So we would see if there is anything in the status of the institutions, if there are any contracts that might hamper the transfer of owned funds or also the repayment of liabilities. But what is really the most important point in this regard is the role of the IPS. I mean, normally, if there is a need for support, the IPS would have an intermediate role to organize the support and to channel also liquidity of funds. And this needs to be taken into account in this regard, that it's really not comparable with the group and the conditions that are set out for the group. So I want to come back possibly to the issue that was just addressed by the need to or the possibility to introduce more funds into money, into the funds. That brings back also this question on the commitment of the IPS to support. I mean, you have put here a very strong sentence that the IPS should not be allowed to refuse to provide support measures if that would lead to the insolvency. Now, the fund is completely already depleted. If there is no money in the fund, it would, in fact, cause that the whole, it would create a whole default of a single institution could trigger then also the default of the whole IPS. Wouldn't that also go a bit too far? Yes, I mean, as I said, in a way, the stability of the IPS and the individual or other members has to be taken into account. But then on the other side, we have the clear text in the CRR that the IPS is there to prevent bankruptcy. So in a way, we have tried to find this kind of wording that is appropriate. So there is indeed a very strong expectation and there should be a commitment to provide support when necessary and there should be the financial capability. But of course, I mean, the support to an individual bank could have some limits. And then some other options might be required, resolution or liquidation. But I mean, this is the wording. And as I said, we are certainly looking into the wordings very carefully. This text that you referred to is probably not in the criteria itself. But Esther can, I'm confident. Would need to check now if it's in the document. But I know that the sentence is there. But I mean, of course, there would also always be the need to assess all these individual cases also, the support cases individually. I mean, there is no blueprint or you cannot already decide now what should happen for all in every support case in the future. Whoever. No, no. Go ahead. Ben, good morning. Ralph Benner, German cooperative banks. Just to stress one topic, which is, from our point of view, very important. After reading the consultation documents, we have got the impression that some of the points which are in these documents might go deep into detail on the level of a single bank, which is more or less a micro management level. We want to comment this in our written statement, but we want to show our concerns in one example. When you look inside the documents on article 137, which C and there, single the point 4, there is defined. And we agree very much with this that an IPS should define common risks and risk categories. Absolutely correct and essential. But then you added some points which are, from all point of view, far too detailed. For example, that you write there to have one common confidence level and one common time horizon for measuring risks. We don't think that this is necessary for banks which are legally independent in an IPS. It is important to have an overall monitoring process, to have a view on these topics, but not to define such a detailed level for a single bank within an IPS. Yes, I mean, as I mentioned already before, I mean, the idea is not to standardize completely the risk management of single institutions. But on the other hand, there has to be comparability of the information. So if one bank is reporting apples to the center and the other one oranges, it doesn't work. So I mean, the key risk measures that are collected centrally and monitored by the center and then leading to the risk classification of the individual members, leading to the early warning signals that are needed, those key measures would have to be comparable. And this point is really intended to ensure comparability. I mean, for instance, if you have a credit risk measure with different confidence level used or different time horizons, you don't have comparability. But of course, we will take on board these comments and review the comments where you think that the criteria are going into too much detail. So of course, we will review those. So we'd be very happy to really have the individual points concretely. Just a spontaneous reaction. From our point of view, the risk of an IPS is not the single risk of a single business done by a bank. The risk of our IPS are the banks themselves. And we have figures and measures to monitor and to judge the risk of the bank as a whole, not on the level of the single contract signed by a bank, not on the level of the confidence that the bank uses to judge if their own business are OK, because the bank itself has to fulfill all the official regulation and rules of a normal bank. So we have to divide between these two perspectives looking on a bank. Yes, I mean, yes, maybe one thing to clarify is that we have to have this comparable monitoring or risk measurement in place so that the different banks in the IPS can be monitored on a comparable basis. So that's clear. But then on the other hand, the bank itself is independent and can also have some additional risk management measures for its own use that is suited to the particular businesses. And it's very much tailored for the needs of the management of that bank. So this is absolutely possible. But the key is that we need to have something that is strong and comparable across institutions. But the individual banks can also have some additional measures, of course, in the risk management. Good morning, Michel Bilger, Crédit Agricole. I have a question on the criteria H of the CRR, article 113.7. It refers to the homogeneous business model of the banks of the network. Could you clarify, because it's not really clear, how you will assess this? Especially in two cases, if you have a network of banks with banks more specialized in one area on corporate business and the other on retail, is it an obstacle? And another case is if you have a capital market which concentrates the inflows and outflows of the IPS for the treasury side, is it an obstacle? Thank you. Thank you very much. On this issue, we in a way concluded that it's not possible to define some quantitative thresholds to address the criteria of homogeneous business profile. What is important is that when there are different kind of institutions inside the IPS, banks that are very different in size and very different in the business approaches, then there should be a sort of common link that these activities should be, in a way, linked to the network of banks that are in the IPS. There can be some services for the IPS members. And then we should be looking at the amount of business that is completely disassociated with the business of the IPS majority members and the IPS network. Esther, you'd like to add something on this? We see also a link of this condition, again, to the risk monitoring by the IPS. So what is really important is even if there are perhaps different activities by the member institutions, the IPS still needs to be in the position to assess the risk of this institution. So the systems of the IPS need to be then appropriate to cover all these different kind of activities and institutions. But I mean, it's clear that there is also some question of cooperation within the IPS networks and that there might be some specifications in some institutions in these groups and that not everybody is really doing exactly the same. I think there is another question in the back. Piotr Bednarski again. Juka, as a former supervisor, I also look at the question of powers of supervisor. And here there is a context of IPS having sufficient power over, as we call it, free riders or against those who exercise moral hazards. Everything is very fine here. And I think there should be some measures which are applicable. The question is what kind of measures and to what kind of intervention, to what depth of intervention we should allow. Because on the other hand, we've got also supervisors who have superpowers, nuclear powers. So where is this balance? Because on one hand, I saw the IPS contract, for example, where there are powers are huge, including the monetary penalties imposed on the individual CEO of cooperative banks, including monetary penalty imposed on the institutions, not to say expulsion from the association, from the IPS. How would you judge this sufficiency of the powers of the IPS? And the second question is also this refers to homogeneity and the question of the proportionality, because in many IPSs there are natural, non-homogeneous situation. You've got central bank, which has oftentimes robust international operations with a lot of trading, oftentimes not very, I would say, secure trading. And this story repeats every 10 years. That's one of the central bank of the association took too much risk in London, and we've got losses. And the cooperative banks are angry that they had to pay again, et cetera. So how would you apply proportionality in that respect? Because some groups won't be homogenous. That's from the definition, because of central bank being much more powerful, having more, much more business at different type of business. And small banks oftentimes were limited. So powers of the IPS, how would you look at that? And the question of homogeneity, thank you. Yes, thank you. Thank you. I mean, in a sense, this is a question that is not easy to answer at this stage, because we are in an early stage. We are just starting the joint monitoring of the IPS together with the NCAs. We did have a look at the governor's structures in this review of IPS that we did before, but we don't have a lot sort of supervisory assessment of the governance, how it works, and what would be our recommendations or requirements or input to the IPS. So this remains to be seen. I mean, it's a delicate issue in the sense that this is not a group where the center can demand something from the individual institutions. This is a bunch of autonomous institutions. So there is a limit, of course, to the powers of the center. But on the other hand, there should be a clear governance framework. There should be a framework what happens in the case of a support. And there should be also the ability to steer and ask the information from the IPS. So there should be a possibility to influence, and also a possibility to influence at an early stage. But how this is actually done, it is too early to comment. Good morning, Emanuele Spina from the Italian Association of Corporative Banks. We have a question regarding the setting up of new IPSs, so the constitutions or the application for a new IPS. And the question comes from the consideration that the experience tells that the financial capacity of an IPS is built through time, obviously. So then the question is, how would you intend to assess the funding capacity of a new IPS? Or is there going to be some room for flexibility until a floor is reached? So if you can tell us some indications about this. Thank you. Yes, I would think that there is, again, a sort of case-by-case assessment. I mean, we think that the Exante fund should be available, and then there should be also the overall assessment of the sufficiency of the funds for support. But I mean, if there's a new IPS that starts from scratch, the fund can have a transitional period. Unless you have something else to add on that, so it's a big deal. Perhaps. But of course, when we assess, for example, the condition that there are funds readily available is fulfilled. It needs to be taken into account what is already there and available in the funds. And I don't think, personally, that it's possible to grant all these permissions when there is nothing available at the moment. I mean, how this is then going to be built up? This is a different question. But some level of security or funds need to be there also in the beginning. Christoph Rübenacker, representing the IPS of the cooperative German banks. We try to find out whether your proposal covers exactly what is written in the CR 137. And just to give you one example, we ask ourselves concerning point D, whether the risk reviews you are describing there is responsible for the whole sector or whether the risk reports have to be given out to all the member banks. The BVR, we've got our own classification system. And of course, every bank gets their own classification. But we've got the question whether you really mean that you want us to give the whole risk review of the whole sector to each individual bank. Because we think it's more important to give them their own individual classification, but not the risk review of the whole system itself. So this is one point where we ask whether the CRR is covered exactly. That's meaning. I mean, I think, as you say, of course, the minimum is that the individual bank gets the information. And then it depends how the system is organized. There can be some kind of a committee that reviews the risk position of individual banks. They need to receive the information. But the full distribution, Esther, I leave that to you what we meant in the guideline. I think what we have in mind is also that the individual members of the IPS should also have some information on the overall situation of the IPS as a whole. I mean, the level of detail can be discussed. But to understand also the risks for the IPS or the potential contribution of the individual members, I think it's also necessary to get some kind of overview. But of course, the main point is that the institutions are informed on their classification. I mean, this is. OK, that seems to be a point that we should be clarifying. Good. Are there any more questions in the room? There is. Thank you. Hello, my name is Otto Reisenberger for Reiverson Central Bank. You told us in your starting statement that you are not going to challenge the decisions of the NCA's. And well, with respect to the original decision, I think in our case, all the requirements which are now included in this consultation paper are already incorporated in the various conditions. But anyway, it's quite interesting for us in which situation you think about reassessing the reasons for the granting of the IPS. And therefore, to bring it to the point, would be, for example, the participation of a new member in the IPS or the exit of a member or the merger of a member and a non-member also lead to reassessment of the entire IPS decision. Or do you have a clear focus on situations when you are going to reassess the original IPS decision of the NCA? Yes, it is true. And as I said in the beginning that the earlier permissions are fully respected and there's no objective to start a fully fledged review of the previous decisions. But then, I mean, if there's a major structural change in the IPS, if it's just one member joining, that may not be a major structural change. But if there's a significant change, then you might have to reassess whether the criteria met. Or if there's an incident in the IPS that gives a reason to the supervisors to think that the IPS is not functioning in the way it should be according to the criteria. So in these cases, you might have to assess the compliance as well. And then there is the ongoing monitoring that the, for instance, the risk monitoring system is well functioning. And then we have some additional decisions that might have to be taken for the already existing IPS. For instance, if the IPS asks for waivers over the liquidity requirements at the level of individual banks and asks the liquidity to be assessed at the global level, then you would have to assess whether the conditions for that are met. This is not the sort of automatic decision coming from the IPS recognition as such, like the 0% risk weight for interbank exposures. That is an automatic. So once an IPS is recognized, there is automatically the 0% risk weight, but not automatically the liquidity waiver. So that we would have to assess whether the conditions are there to have this kind of waiver. Thank you. Yes, it's well understood that, for example, for the waiver, there would be an additional application. But do you have a clear focus on when you're going to reassess the IPS decision itself? No. I mean, we don't have any plan to review the past decisions. It's not our focus to go through the past decisions and reassess them. But it will be case by case. I mean, if something is coming up from the regular monitoring of the IPS, or if there is a major structural change or incidents, then that might trigger the supervisory assessment. But the change of a member might not automatically be a major structural change. No. No. If it's depends on the member, yes. What is classified as a significant change. If it's one bank in the valley of Austria, then it may not be. But it may not be in one valley of Austria. Holger Mielk, also representing the German corporate banks. May I add one question to what my previous speaker asks. Have I understood you're right that, for example, if we ask for the waiver from Article 49, Par 3 from the CRR, that that might lead to a new assessment of the fulfilling of the requirements of Article 130, Par 7? No. I didn't mean that. What I meant was, and I hope I was clear, because I thought I had a clear answer, that it is the individual assessment of whether that waiver could be granted. It's not the assessment of the past criteria. But if it's the liquidative waiver, then of course you have to assess whether the liquidities will manage at the level of the IPS, whether there's free movement of liquidative and needed, whether there's support coming if one bank is losing liquidity. I mean, this kind of thing that is related to the issue itself. Great. Unless there is another last minute question, I think we have come to an end. Thank you very much, everybody, for coming and for asking interesting questions and bringing forward your suggestions. And as Yuka said a couple of times, send in your comments in writing that's always much easier to assess them and to put them into the process so that we can take them into account and have a look at them. Thanks a lot, and have a safe travel home. Yes, thank you very much also from our side and looking forward to receiving further comments. Thank you very much.