Notice 2023 relative aux modalités de calcul et de publication des ratios prudentiels dans le cadre de la CRD IV et exigence de MREL (version du 7 juillet 2023)

The present Notice 2023 aims to promote transparency and predictability in the calculation and publication of prudential ratios within the scope of CRD IV and MREL. The notice incorporates regulations stemming from EU directives and regulations, including CRR, CRR2, CRD IV, IFR, IFD, and BRRD, which align with the standards set by the Basel Committee in the European context.
The notice clarifies the supervisory responsibilities of the ACPR and designates the ECB as the competent authority for significant credit institutions under the SSM since 4 November 2014. The BCE’s role involves implementing and supervising the CRD IV’s options and discretions for significant institutions, while the ACPR remains the competent authority for entities not directly supervised by the BCE within the SSM.
It provides guidance and explanations to credit institutions, investment firms, financial companies, and holding companies collectively referred to as „the Establishments.“ The ACPR aims to act proportionally based on the BCE’s explanations and recommendations for institutions subject to CRR/CRD IV and under its supervision.
The notice highlights the significance of the BTS published on the EBA website, which complement the CRD IV. Although the BTS are not legally binding, the ACPR considers them as important references until any potential objections from the European Commission.
The document primarily focuses on the Pillar 1 requirements, which encompass solvency, liquidity, and leverage ratios. However, it does not delve into the detailed requirements of the ICAAP, ILAAP, and SREP methodologies. Nevertheless, it briefly addresses the management of IRRBB and provides an overview of financial communication under Pillar 3. Furthermore, the notice outlines the MREL requirements derived from the BRRD and SRMR, which associates a SRM with CRD IV.
The „Notice 2023“ acknowledges its limitations and evolving nature, as it cannot encompass all aspects of the covered ratios, due to the evolving regulatory landscape and changing banking practices. To enhance transparency, EBA centralizes relevant information, including lists of public sector actors treated as exposures to regional or central administrations, specific risk treatments in certain jurisdictions, and other supervisory disclosures.
Of note, the ACPR also provides an edition with tracked changes of Notice 2023, thereby allowing interested entities to see changes introduced into the current version of 7 July 2023 versus the initial version of 13 July 2022.