EBIC notes that it is the belief of all member associations of
EBIC that the White Paper goes in the right direction, and sets the right objectives. However,
EBIC urges the Commission to make clear the steps and timing of the process that it aims to employ in implementing its better regulation approach for each case of legislative initiative. In order to achieve a satisfactory regulatory outcome, it is essential that this approach also be embraced by the European Parliament and the Council. The said approach should also be followed at level 2 of the Lamfalussy process and more generally whenever comitology is being used.
With regards to future initiatives, and specifically in the area of bank accounts, EBIS states among others that the Commission should strive to avoid over-regulation as well as avoid the kind of proposals that risk imposing unnecessary costs either on the industry or on consumers - such as portability of bank accounts.
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