ESA’s tough final Regulatory Standards on conglomerate capital are out.
This is complicated material. But … looking at Article 9 of this standard, the bar for recognition of supplementary capital looks high. Even though it applies after the entry into force of Regulation (EU) No 575/2013 (CRR) and only when both CRR and Solvency (2009/138/EC) apply.
The requirements are stacked up high!
Article 9 says basically this: a solvency requirement means for banks:
- the requirements of CRR and CRD to hold capital in excess of those requirements (the normal capital requirements),
- including a requirement arising from the (ICAAP, following Article 73 of the Directive),
- any requirement imposed by a competent authority pursuant to Article 104(1)(a) of that Directive (Second Pillar),
- the combined buffer requirement as defined in Article 128(6) of that Directive (Conservation, Cyclical, and SIB buffers),
- and measures adopted according to Articles 458 (macroprudentially inspired) or 459 (prudential requirements) of Regulation (EU) No 575/2013.