The European Savings Banks Group (ESBG) believes that the proposed new Capital Adequacy Directive should be applied on a universal, positive basis, rather than on a voluntary one. The
ESBG has identified five major reasons why a voluntary implementation method would be inappropriate in the European context.
The ESBG believes that:
The universal implementation of the Directive in Europe is consistent with the aims of
the European single market and monetary union;
The revised Accord and the provisions for a new Directive allow for the size and level of
risk assumed by the financial institution;
The voluntary implementation approach could potentially lead to the concentration of
riskier exposures in the ‘Basel I’ sector;
The aims of the Directive in terms of regulatory arbitrage are as applicable to large as to
small banks;
The voluntary implementation of the Accord would be detrimental to the strategic
interests of European banks in the future development of regulatory provisions.
Press release
Position Paper
© European Savings Banks Group
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