Opinion of the European Central Bank of 27 March 2014 on the measurement of credit and country risk of bank groups (CON/2014/23)
Date: 2014-03-27
Institutions: European Central Bank
Subjects: Austria, credit institution, financial risk, financial stability, national law, statistics, subsidiary

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 27 March 2014 

on the measurement of credit and country risk of bank groups 

(CON/2014/23) 

Introduction and legal basis 

On  25  February  2014,  the  European  Central  Bank  (ECB)  received  a  request  from  the  Oesterreichische 

Nationalbank (OeNB) for an opinion on a draft regulation on the detection of credit and country risk of 

groups of credit institutions and their foreign subsidiaries (hereinafter the ‘draft regulation’). 

The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the 

Functioning  of  the  European  Union  and  the  third,  fourth  and  sixth  indents  of  Article  2(1)  of  Council 
Decision 98/415/EC1, as the draft regulation relates to the OeNB, the collection of financial statistics and 

contains  rules  applicable  to  banks  which  materially  influence  the  stability  of  financial  institutions  and 

markets. In accordance with the first sentence of Article 17.5 of the Rules of Procedure of the European 

Central Bank, the Governing Council has adopted this opinion. 

1. 

Purpose of the draft regulation 

1.1  The purpose of the draft regulation is to detect credit and country risk of Austrian groups of credit 

institutions  and  their  foreign  subsidiary  banks.  It  applies  to  superordinate  credit  institutions  of 

Austrian groups of credit institutions within the meaning of Article 30(5) of the Law on banking. 

Such superordinate credit institutions will be required to submit reports on credit and country risk 

to the OeNB on a quarterly basis. Reports are to be submitted in accordance with the four annexes 

to the draft regulation: (1) consolidated risk statement on credit risk (Annex A1), (2) risk statement 

on  the  credit  risk  for  foreign  subsidiary  banks  (Annex  A2),  (3)  consolidated  risk  statement  on 

country  risk  (Annex  B1)  and  (4)  risk  statement  on  the  country  risk  of  foreign  subsidiary  banks 

(Annex B2). The draft regulation will enter into force on 1 July 2014 and will apply, for the first 

time, to reports on 30 September 2014. 

1.2  Article 44b(1) of the Law on Oesterreichische Nationalbank (hereinafter the ‘Law on the OeNB’) 

requires  the  OeNB  to  monitor,  in  the  public  interest,  all  matters  that  may  have  an  impact  on 

safeguarding financial stability in Austria. In general, and based on a current reporting regulation of 

the  Austrian  Financial  Market  Authority  (FMA)  on assets,  profits  and  risks  of  credit  institutions, 

the FMA makes available the data necessary for the OeNB to fulfil this task. The FMA regulation 

1  

Council Decision 98/415/EC of 29 June 1998 on the consultation of the European Central Bank by national authorities 
regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42). 

 
 
 
 
                                                            
ECB-PUBLIC 

currently provides for the reports required under the draft regulation. Following implementation of 
the CRD IV package2 and the reporting implementing technical standards of the European Banking 

Authority, with effect from the third quarter of 2014, the FMA will no longer collect data on credit 

and  country  risk  of  groups  of  credit  institutions.  However,  the  OeNB  needs  this  data  in  order  to 

continue  to  carry  out  its  tasks  in  connection  with  the  maintenance  of  financial  stability. 

Accordingly, the OeNB envisages issuing the draft regulation on the basis of Article 44b(2) of the 

Law  on  the  OeNB  in  order  to  collect  information  on  credit  and  country  risk  of  groups  of  credit 

institutions and their foreign subsidiary banks. 

2. 

General observations 

The  ECB  understands  that  the  draft  regulation  implements  statistical  data  collection  powers  at  the 

disposal  of  the  OeNB  under  the  Law  on  the  OeNB,  to  be  applied  in  an  area  which  is  not  presently 

harmonised  through  a  Union  legal  act  in  the  field  of  statistics.  In  this  context,  the  ECB  points  to  its 
Decision  ECB/2014/63,  establishing  measures  aimed  at  gradual  development  of  the  ECB  statistical 

framework  in  relation  to  the  credit  exposures  of  credit  institutions,  or  other  loan-providing  financial 

institutions,  vis-à-vis  borrowers.  Such  prospective  statistical  framework  will  serve  the  purpose  of,  inter 

alia, supporting the activities of the European System of Central Bank in the area of financial stability. 

The ECB invites the Austrian authorities to monitor the development of this ECB statistical framework, 

which framework may interact with the objectives of the draft regulation.  

This opinion will be published on the ECB’s website. 

Done at Frankfurt am Main, 27 March 2014. 

[signed] 

The President of the ECB 

Mario DRAGHI 

2  

3  

Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements 
for credit institutions and investment firms and amending Regulation (EU) No 648/2012 (OJ L 176, 27.6.2013, p. 1) and 
Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit 
institutions  and  the  prudential  supervision  of  credit  institutions  and  investment  firms,  amending  Directive  2002/87/EC 
and repealing Directives 2006/48/EC and 2006/49/EC (OJ L 176, 27.6.2013, p. 338). 
Decision  ECB/2014/6  of  24  February  2014  on  the  organisation  of  preparatory  measures  for  the  collection  of  granular 
credit  data  by  the  European  System  of  Central  Banks,  available  at  the  ECB  website  (www.ecb.europa.eu);  not  yet 
published in the Official Journal. 

2