18 January 2008

EBF response to 3L3 Work Programme consultation

In its response to the 3L3 Work Programme consultation the EBF urges the 3L3 to capitalise on the not inconsiderable political will to make progress on improving supervisory co-operation within Europe. The issues identified are to be generally aligned with the recommendations arising from the recent review of the Lamfalussy Process.

EBF believes that the 3L3 should focus on improving supervisory cooperation and convergence within the Committees as a necessary pre-condition to ensuring efficient cooperation and convergence across the three sectors.

Pointing to the 3L3 mission statement, for 2008-2010 the 3L3 should, among others,

•  aim at a fully harmonised and consistent implementation of regulation throughout the EU, with no national option and discretions in the prudential area or room for gold plating in general, to thereby avoid divergent national interpretations and implementations;

• contribute to achieving a consistent approach to supervision on the basis of colleges of supervisors.

Also, the 3L3 should be made accountable to the EU institutions and report to them on the degree of supervisory convergence achieved.

© EBF