Annexes to COM(2015)586 - Amendment of Regulation (EU) 806/2014 in order to establish a European Deposit Insurance Scheme

Please note

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Agreement of 25 May 1999 between the European Parliament, the Council of the European Union and the Commission of the European Communities concerning internal investigations by the European Anti-Fraud Office (OLAF) and shall immediately adopt appropriate provisions for all Board staff.

The funding decisions and the agreements and the implementing instruments resulting from them shall explicitly stipulate that the Court of Auditors and OLAF may, if need be, carry out on-the-spot checks at the beneficiaries of money disbursed by Board as well as on the staff responsible for allocating this money.

Articles 61-66 of the Regulation set out the provisions on implementation and control of the Board’s budget and applicable financial rules.

8. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

The analysis below provides an estimation of the overall costs for the Board and its administration. No costs are expected for the EU budget since all expenses of the board will be fully financed by the approximatley 6,000 financial institutions covered by EDIS. The calculation method will be based on size and will be set out in a delegated act in 2016. For reasons of conistency, the same methodology should be applied under EDIS.

The tasks of the Board will be limited as regards Deposit Insurance. EDIS will evolve over the following three phases: (i) reinsurance, (ii) co-insurance and (iii) full insurance. In all phases, the Board will need to assess whether the requesting DGS complies with a number of provisions of Directive 2014/49/EU, notably whether it has built up its national fund. Different from the Board’s function in resolution, there is no discretionary element in its decision, since the payment obligation of the participating DGS towards depositors (compensation) or towards a resolution authority (contribution to resolution) follows the determination of an administative or judicial authority.

In the first phase, the Board will assess requests for reinsurance cover and and provide the necessary funding to compensate national DGS within the limits of coverage. These tasks remain the same under the co-insurance phase, but, all other things being equal, one may expect a higher number of potential cases as the preconditions for coverage by EDIS are less restrictive than in the reinsurance period. Under full-insurance, the tasks of the Board would increase significantly. In addition to respond to requests for coverage, it would need to calculate and collect contributions from individual banks and manage the European Deposit Insurance Fund. These tasks are similar to tasks under the Single Resolution Mechanism. Hence siginifcant economies of scale can be expected and the increase in tasks does not result in a proportionately increasing need for staff.

The staffing of DGS depends on the scope for the interventions. Some DGS have the possibility to use their funds for measures which would prevent institutions from failing, i.e. avoiding pay-out events in the first place. DGS with such possibility also have broader risk monitoring and management capabilities than DGS which mainly serve as ‘paybox’ to compensate depositors. The scope for EDIS would be limited to financially assist national DGS in such paybox function.

There is little publically available information on the staff levels of national DGS. A survey by the European Forum for Deposit Insurers indicates that levels for direct (i.e. without support functions) staff ranges between 10 and 40 FTE for such DGS with comparable functions to EDIS.

In view of the limited, but gradually increasing tasks of EDIS, the Commission proposes the following FTE for direct functions

• Under Reinsurance: 5 FTE (+ 0.5 FTE overhead)

• Under Co-insurance: 10 FTE (+1 FTE overhead)

• Under full insurance: 20 FTE (+2 FTE overhead)


Table: Indicative development of FTEs

Human Resources20172018201920202021202220232024
Establishment plan posts: AD444488816
Establishment plan posts: AST0.50.50.50.51112
Establishment plan posts: AST/SC00000000
Total establishment plan posts4.54.54.54.599918
Contract agents0.50.50.50.51112
Seconded national experts0.50.50.50.51112
Total staff5.55.55.55.511111122


DG FISMA currently has a ratio of overhead staff of 11.2 per cent. It is expected that for EDIS significant economies of scale can be achieved with the resolution functions of the board, notably in human resources management, the calculation and collection of contributions and the management of the fund. A 9% overhead ratio therefore seems feasible.


Table: Indicative development of expenditure

Expenditure20172018201920202021202220232024
Title 1: Staff expenditure6586586586581,3151,3151,3152,631
Title 2: Infrastructure and operating expenditure50505050110110110220
Title 3: Operational expenditure116116116116232232232464
Total8248248248241,6571,6571,6573,315


Main assumptions

Building on what has been assessed for the resolution function of the Single Resolution Board, the following distribution of personnel is suggested:

• 80% of TAs (68% of ADs and 12% of ASTs);

• 10% of ENDs;

• 10% of CAs.

Staff Regulation of EU institutions will be applied, which is reflected in the used per head rates:

• average yearly cost of a TA: EUR 131,000;

• average yearly cost of an END: EUR 78,000;

• average yearly cost of a CA: EUR 70,000.

In addition to the salary, this cost includes indirect costs such as building, training, IT and socio-medical infrastructure costs.

Since the Board has its seat in Brussels, a salary correction coefficient of 1 is used.

Operational expenditures are expected to amount to 15% of total Board’s costs. This is significantly lower than the 25% estimated for the resolution function, since it is expected that costs for the development and maintenance of information systems and internal services could be shared with the resolution function.


8.1.Heading(s) of the multiannual financial framework and expenditure budget line(s) affected


No impact on the Union's budget.


• Existing budget lines

In order of multiannual financial framework headings and budget lines.

Heading of multiannual financial frameworkBudget lineType of
expenditure
Contribution
Number
[Heading………………………...……………]
Diff./Non-diff. 17from EFTA countries 18

from candidate countries 19

from third countrieswithin the meaning of Article 21(2)(b) of the Financial Regulation
[XX.YY.YY.YY]

Diff./Non-diff.YES/NOYES/NOYES/NOYES/NO

• New budget lines requested

In order of multiannual financial framework headings and budget lines.

Heading of multiannual financial frameworkBudget lineType of
expenditure
Contribution
Number
[Heading………………………………………]
Diff./Non-diff.from EFTA countriesfrom candidate countriesfrom third countrieswithin the meaning of Article 21(2)(b) of the Financial Regulation
[XX.YY.YY.YY]

YES/NOYES/NOYES/NOYES/NO

8.2.Estimated impact on expenditure


No impact on the Union's budget.

8.2.1.Summary of estimated impact on expenditure

EUR million (to three decimal places)

Heading of multiannual financial
framework
Number[Heading……………...……………………………………………………………….]

DG: <…….>Year
N 20
Year
N+1
Year
N+2
Year
N+3
Enter as many years as necessary to show the duration of the impact (see point 1.6)TOTAL
• Operational appropriations
Number of budget lineCommitments(1)
Payments(2)
Number of budget lineCommitments(1a)
Payments(2a)
Appropriations of an administrative nature financed from the envelope of specific programmes 21  

Number of budget line(3)
TOTAL appropriations
for DG <…….>
Commitments=1+1a +3
Payments=2+2a

+3


• TOTAL operational appropriations
Commitments(4)
Payments(5)
• TOTAL appropriations of an administrative nature financed from the envelope for specific programmes
(6)
TOTAL appropriations
under HEADING <….>
of the multiannual financial framework
Commitments=4+ 6
Payments=5+ 6

If more than one heading is affected by the proposal / initiative:

• TOTAL operational appropriations
Commitments(4)
Payments(5)
• TOTAL appropriations of an administrative nature financed from the envelope for specific programmes
(6)
TOTAL appropriations
under HEADINGS 1 to 4
of the multiannual financial framework
(Reference amount)
Commitments=4+ 6
Payments=5+ 6


Heading of multiannual financial
framework
5‘Administrative expenditure’

EUR million (to three decimal places)

Year
N
Year
N+1
Year
N+2
Year
N+3
Enter as many years as necessary to show the duration of the impact (see point 1.6)TOTAL
DG: <…….>
• Human resources
• Other administrative expenditure
TOTAL DG <…….>Appropriations

TOTAL appropriations
under HEADING 5
of the multiannual financial framework 
(Total commitments = Total payments)

EUR million (to three decimal places)

Year
N 22
Year
N+1
Year
N+2
Year
N+3
Enter as many years as necessary to show the duration of the impact (see point 1.6)TOTAL
TOTAL appropriations
under HEADINGS 1 to 5
of the multiannual financial framework 
Commitments
Payments

8.2.2.Estimated impact on operational appropriations

– ◻    The proposal/initiative does not require the use of operational appropriations

– ◻    The proposal/initiative requires the use of operational appropriations, as explained below:

Commitment appropriations in EUR million (to three decimal places)

Indicate objectives and outputs



Year
N
Year
N+1
Year
N+2
Year
N+3
Enter as many years as necessary to show the duration of the impact (see point 1.6)TOTAL
OUTPUTS
Type 23

Average costNoCostNoCostNoCostNoCostNoCostNoCostNoCostTotal NoTotal cost
SPECIFIC OBJECTIVE No 1 24
- Output
- Output
- Output
Subtotal for specific objective No 1
SPECIFIC OBJECTIVE No 2 ...
- Output
Subtotal for specific objective No 2
TOTAL COST

8.2.3.Estimated impact on appropriations of an administrative nature

8.2.3.1.Summary

– ◻    The proposal/initiative does not require the use of appropriations of an administrative nature

– ◻    The proposal/initiative requires the use of appropriations of an administrative nature, as explained below:

EUR million (to three decimal places)

Year
N 25
Year
N+1
Year
N+2
Year
N+3
Enter as many years as necessary to show the duration of the impact (see point 1.6)TOTAL

HEADING 5
of the multiannual financial framework
Human resources
Other administrative expenditure
Subtotal HEADING 5
of the multiannual financial framework

Outside HEADING 5 26
of the multiannual financial framework

Human resources
Other expenditure
of an administrative nature
Subtotal
outside HEADING 5
of the multiannual financial framework

TOTAL

The appropriations required for human resources and other expenditure of an administrative nature will be met by appropriations from the DG that are already assigned to management of the action and/or have been redeployed within the DG, together if necessary with any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary constraints.

8.2.3.2.Estimated requirements of human resources

– ◻    The proposal/initiative does not require the use of human resources.

– ◻    The proposal/initiative requires the use of human resources, as explained below:

Estimate to be expressed in full time equivalent units

Year
N
Year
N+1
Year N+2Year N+3Enter as many years as necessary to show the duration of the impact (see point 1.6)
• Establishment plan posts (officials and temporary staff)
XX 01 01 01 (Headquarters and Commission’s Representation Offices)
XX 01 01 02 (Delegations)
XX 01 05 01 (Indirect research)
10 01 05 01 (Direct research)
• External staff (in Full Time Equivalent unit: FTE) 27

XX 01 02 01 (AC, END, INT from the ‘global envelope’)
XX 01 02 02 (AC, AL, END, INT and JED in the delegations)
XX 01 04 yy  28

- at Headquarters

- in Delegations
XX 01 05 02 (AC, END, INT - Indirect research)
10 01 05 02 (AC, END, INT - Direct research)
Other budget lines (specify)
TOTAL

XX is the policy area or budget title concerned.

The human resources required will be met by staff from the DG who are already assigned to management of the action and/or have been redeployed within the DG, together if necessary with any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary constraints.

Description of tasks to be carried out:

Officials and temporary staff
External staff

8.2.4.Compatibility with the current multiannual financial framework

– ◻    The proposal/initiative is compatible the current multiannual financial framework.

– ◻    The proposal/initiative will entail reprogramming of the relevant heading in the multiannual financial framework.

Explain what reprogramming is required, specifying the budget lines concerned and the corresponding amounts.


– ◻    The proposal/initiative requires application of the flexibility instrument or revision of the multiannual financial framework.

Explain what is required, specifying the headings and budget lines concerned and the corresponding amounts.


8.2.5.Third-party contributions

– The proposal/initiative does not provide for co-financing by third parties.

– The proposal/initiative provides for the co-financing estimated below:

Appropriations in EUR million (to three decimal places)

Year
N
Year
N+1
Year
N+2
Year
N+3
Enter as many years as necessary to show the duration of the impact (see point 1.6)Total
Specify the co-financing body 
TOTAL appropriations co-financed


8.3.Estimated impact on revenue

No impact on the Union's budget.

– ◻    The proposal/initiative has no financial impact on revenue.

– ◻    The proposal/initiative has the following financial impact:

on own resources

on miscellaneous revenue

EUR million (to three decimal places)

Budget revenue line:Appropriations available for the current financial yearImpact of the proposal/initiative 29
Year
N
Year
N+1
Year
N+2
Year
N+3
Enter as many years as necessary to show the duration of the impact (see point 1.6)
Article ………….

For miscellaneous ‘assigned’ revenue, specify the budget expenditure line(s) affected.


Specify the method for calculating the impact on revenue.


(1)

   Communication from the Commission to the European Parliament and the Council ‘A Roadmap towards a Banking Union’, COM(2012) 510, 12.9.2012.

(2)

   Five Presidents' Report of 22 June 2015 on "Completing Europe's Economic and Monetary Union" http://ec.europa.eu/priorities/economic-monetary-union/docs/5-presidents-report_en.pdf

(3)

   Communication from the Commission to the European Parliament, the Council and the European Central Bank on steps towards Completing Economic and Monetary Union, COM(2015) 600 final 21.10.2015.

(4)

   Council Regulation (EU) No 1024/2013 of 15 October 2013 conferring specific tasks on the European Central Bank concerning policies relating to the prudential supervision of credit institutions OJ L 287, 29.10.2013, p. 63–89.

(5)

   Regulation (EU) No 806/2014 of the European Parliament and of the Council of 15 July 2014 establishing uniform rules and a uniform procedure for the resolution of credit institutions and certain investment firms in the framework of a Single Resolution Mechanism and a Single Resolution Fund and amending Regulation (EU) No 1093/2010 OJ L 225, 30.7.2014, p. 1–90.

(6)

   Directive 2014/49/EU of the European Parliament and of the Council of 16 April 2014 on deposit guarantee schemes, OJ L 173, 12.6.2014, p. 149–178.

(7) Payment of the difference amount under Article 75 of Directive 2014/59/EU: it is assumed that this rule applies by analogy also in SRM resolution cases under Article 79.
(8) A graph comparing the evolution of the funds of EDIS to the evolution of the funds of a participating DGS, in case the Member State and the participating DGS choose to compensate member banks for the ex-ante contributions paid to EDIS, can be found on the Commission's website: http://ec.europa.eu/finance/general-policy/banking-union/european-deposit-insurance-scheme/index_en.htm
(9) OJ C , , p. .
(10) OJ C , , p. .
(11) Council Regulation (EU) No 1024/2013 of 15 October 2013 conferring specific tasks on the European Central Bank concerning policies relating to the prudential supervision of credit institutions (OJ L 287, 29.10.2013, p. 63).
(12) Directive 2014/49/EU of the European Parliament and of the Council of 16 April 2014 on deposit guarantee schemes (OJ L 173, 12.6.2014, p. 149).
(13) Regulation (EU) No 806/2014 of the European Parliament and of the Council of 15 July 2014 establishing uniform rules and a uniform procedure for the resolution of credit institutions and certain investment firms in the framework of a Single Resolution Mechanism and a Single Resolution Fund and amending Regulation (EU) No 1093/2010 (OJ L 225, 30.7.2014, p. 1).
(14) ABM: activity-based management; ABB: activity-based budgeting.
(15) As referred to in Article 54(2)(a) or (b) of the Financial Regulation.
(16) Details of management modes and references to the Financial Regulation may be found on the BudgWeb site: http://www.cc.cec/budg/man/budgmanag/budgmanag_en.html
(17) Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations.
(18) EFTA: European Free Trade Association.
(19) Candidate countries and, where applicable, potential candidate countries from the Western Balkans.
(20) Year N is the year in which implementation of the proposal/initiative starts.
(21) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.
(22) Year N is the year in which implementation of the proposal/initiative starts.
(23) Outputs are products and services to be supplied (e.g.: number of student exchanges financed, number of km of roads built, etc.).
(24) As described in point 1.4.2. ‘Specific objective(s)…’
(25) Year N is the year in which implementation of the proposal/initiative starts.
(26) Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.
(27) AC= Contract Staff; AL = Local Staff; END= Seconded National Expert; INT = agency staff; JED= Junior Experts in Delegations.
(28) Sub-ceiling for external staff covered by operational appropriations (former ‘BA’ lines).
(29) As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 25 % for collection costs.