The Banking Supervisory Authority has adopted a number of measures aimed at facilitating the activities of supervised banks and non-bank intermediaries in the context of the ongoing health emergency.

In particular, the measures include the postponement, for a variable duration, of certain obligations relating, inter alia, to the following matters:

1. ICAAP/ILAAP for banks and SIM and ICAAP for financial intermediaries pursuant to Article 106 of Italian Legislative Decree No. 385 dated 1 September 1993;
2. Recovery plans, reports on outsourced functions for banks and financial intermediaries;
3. Reports on the organizational structure for Investment firm, Asset Manager, SICAF, SICAV, Payment Institutions and Electronic Money Institution (where due for significant organizational interventions);
4. Self-assessment of the continuation of the suitability requirements of the custodian;
5. Report of the anti-money laundering function (which includes the risk self-assessment for 2019);
6. Customer Due Diligence (recovery of client data already acquired for anti-money laundering purposes);
7. Report on compliance with the obligations regarding the deposit and sub-deposit of client’s instruments and compliance with the transitional arrangement of the Regulation dated December 5th 2019 implementing the Italian legislative Decree No. 58 of 24 February 1998 (see Article 2, paragraph 2 and deed issuing the Regulation) by intermediaries providing investment services;

It is also permitted, now also for less significant banks and in line with the ECB's decision for significant banks, to operate temporarily below the target component level assigned as a result of the SREP (i.e. Supervisory Review and Evaluation Process), the capital conservation buffer and the liquidity coverage ratio. Upon the occurrence of these circumstances, the Bank of Italy will assess the realignment plans to be submitted by the intermediaries, taking into account the exceptional conditions that have brought the capital and liquidity ratios below the required levels.

The Bank of Italy, which is re-programming the inspection calendars, invites intermediaries to consider and address the risk of the pandemics in emergency plans, evaluating the measures to be taken to minimize the potential adverse effects of the spread of COVID-19.

It is reasonable to expect Consob to take similar measures to extend the deadlines for regulatory obligations expiring during this health emergency period.