ABBL supports the reform of the European supervisory architecture; however, ABBL has some concerns regarding the role of the European Supervisory Authorities.
The Luxembourg Bankers’ Association welcomes the opportunity to comment on the Commission Communication on European financial supervision.
In line with ABBL’s previous comments on the Commission Communication of March 4, 2009, ABBL reiterate its support to the reform of the European supervisory architecture.
However, there are a few concerns that the ABBL would like to highlight. Regarding the role of the European Supervisory Authorities, more precision would be appreciated by the ABBL on the following aspects:
- The circumstances triggering the intervention of the European Supervisory Authorities;
- The articulation of the European Supervisory Authorities’ role and the Level 4 of the Lamfalussy framework, whereby the Commission ensures that Member States are complying with applicable legislation and pursues enforcement action when required.
- The introduction of “emergency decisions”. In an emergency situation the European Supervisory Authorities would not issue implementing measures concerning sectoral directives, but would make a decision of an operational supervisory nature. Such decisions should not be taken in the absence of mandate received from the Council, and they should not impinge on the Member States’ fiscal policies.
- The governance of the European Supervisory Authorities must be clarified.
- These Authorities are technical bodies, which must not be influenced by political considerations. In particular, the voting system should guarantee that decisions are taken in a neutral, effective and timely manner.
© ABBL - Luxembourg Bankers’ Association
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