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Part V Supervisory Review and Evaluation Process and Pillar 2 Capital, 17 The ECB Guide to Internal Liquidity Adequacy: A Principles-Based Approach

Dalvinder Singh

From: Capital and Liquidity Requirements for European Banks (1)

Edited By: Bart P.M. Joosen, Marco Lamandini, Tobias H. Tröger

From: Oxford Legal Research Library (http://olrl.ouplaw.com). (c) Oxford University Press, 2023. All Rights Reserved.date: 30 May 2024

Bank supervision — Credit risk — Securities — Capital requirement — Liquidity

This chapter analyses the European Central Bank Guide to Internal Liquidity Adequacy (ECB ILAAP Guide), which aim to introduce safeguards against liquidity contingency risk from a crisis prevention perspective. While the strategic direction of liquidity management resides with a bank’s management body, it requires delegation down to technical experts to ensure it is operationalized as efficiently as possible. The chapter argues that the crisis prevention narrative is delegated to banks to discharge their obligation in bank supervision so as to minimize the asymmetry of information problems created by their business and improve the way they manage adverse scenarios and the risks to depositors, markets, and supervisory authorities. The ECB ILAAP Guide is simply one component of a complex web of supervisory instruments and tools for banks’ liquidity management. In view of this, it is also important to consider the European Banking Authority (EBA) findings on internal governance from its convergence assessment. The chapter considers how these inform various decision-making processes within the Single Supervisory Mechanism (SSM) such as the work of the Joint Supervisory Teams (JSTs) and Supervisory Review and Evaluation Process (SREP), as the ECB ILAAP Guide specifically emphasizes the traditional qualitative approach to the supervision of liquidity management.

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