Capital add-ons for systemically important financial institutions in Germany
Since 1 January 2017, selected German banks have to meet an additional capital buffer requirement in order to increase their resilience. The intention is for these institutions to become equipped to better absorb potential losses in future. The decision as to which institutions will have to hold such a capital buffer is made jointly by the Bundesbank and the Federal Financial Supervisory Authority (BaFin), acting as Germany's national supervisors. Their decision is based on a methodology which is compliant with international and national standards and the basic features of which have been published. The level of the capital buffer is determined by BaFin. Accordingly, BaFin publishes the list of affected credit institutions as well as the level of the required capital buffer.
The institutions identified are referred to as “other systemically important institutions” (O-SIIs). Unlike global systemically important institutions (G-SIIs), the main factor when classifying an O-SII is the potential risk to the national economy.
Institutions in Germany classified as O-SIIs are identified at least once a year by the Bundesbank and BaFin in a two-step process. In the first step, the institutions are assessed according to a uniform Europe-wide scoring model. This method, prescribed by the European Banking Authority (EBA), ensures that O-SIIs are identified in a comparable and transparent way in all EU member states. In the second step, national supervisory authorities can classify additional institutions as O-SIIs, thus taking into account specificities of the respective national banking system. The method used for step two is updated as necessary, but at least every three years. BaFin publishes the list of O-SIIs as well as the latest version of the method at the end of each year after all administrative procedures have been completed (see the link).
The key factors in this classification are size, relevance for the European and German economy, cross-border activities and the interconnectedness with the financial system.
The provisions of the German Banking Act (Kreditwesengesetz) and the EBA guidelines require publication of the basic features of the method used as well as the institutions affected, their scores and the prescribed capital buffers.