07 October 2011

2011年10月14日～15日のG20財務相会議を控えたEFR（欧州金融サービス・ラウンドテーブル）の書簡

Unfortunately, the outlook for global output and employment growth has darkened over recent months. Recent market movements reflect the widespread uncertainty perceived by households and investors about the future path of global economic developments. As the OECD remarked in its recent Interim Economic Assessment, there is a severe crisis of confidence in economic policies around the globe. In these circumstances, EFR regards it as crucial that G20 finance ministers send again a clear message on their policy goals, the measures needed to achieve them, and the degree of coordination required.

Ministers have recognised the importance of tackling the growth challenge at this time. Over the medium term, a move to sustainable fiscal and monetary policies is essential. However, given that traditional macro-economic policy instruments are constrained in many countries at the moment, it is all the more important for countries to make use of policy measures that support growth without having direct budgetary implications. Trade liberalisation, a convergence of technical industry standards, as well as financial standards and market integration are good examples. A joint G20 declaration on the crucial importance of reinvigorating growth and implementing coordinated policy measures is essential to avoid current downside risks becoming entrenched.

EFR believes that the current policy environment also underscores the need to ensure convergence of international regulatory standards, to ensure that rules focus on activities and risks in a consistent manner, to expand and understand the perimeter of financial regulation to avoid regulatory arbitrage, while at the same time recognising that financial stability is fostered by a diversity of financial actors.

In addition to these general concerns on the economic outlook and regulatory processes, there are three specific issues to which EFR draws attention:

First, as regulation is tightened, incentives to transfer activities into less strictly regulated financial institutions and markets are mounting, increasing significantly the risk of regulatory arbitrage in these market segments. There is a need for comprehensive regulatory approaches that are consistent across markets and across continents.

Second, recognising the crucial importance of realising a single high-quality set of accounting standards for financial stability and market integration, G20 leaders have agreed to achieve convergence by the end of 2011. Convergence of accounting standards will increase transparency and comparability of balance sheets, assist regulators in fulfilling their responsibilities, and help investors in their decision-making. In addition, sound and internationally-accepted accounting standards will contribute to stable financial markets if a single version of accounting standards is adopted by all G20 countries, and indeed, universally.

Third, EFR is seriously concerned about the debate on the imposition of additional taxes on financial services, specifically a financial transactions tax. EFR would recall that several countries in Europe have already introduced specific bank levies or are in the process of doing so. These levies have different tax bases and charges, thereby already creating - in some cases - an environment of double-taxation and competitive distortions in Europe alone. In addition, policy-makers should bear in mind that enacting a financial transactions tax on the financial sector will ultimately hurt returns to savers and investors, particularly those saving for pensions, many of whom will also be taxpayers. The IMF concluded in its report last year to the G20 that the economic impact would largely fall on end-users.

Finally, EFR is concerned about a tendency to transfer regulatory concepts from parts of the financial sector to others without appropriate and sufficient differentiation. EFR recalls that the principle of “same risk, same rules” has proven to be a useful guideline for regulation. It ensures that identical activities are treated likewise, irrespective of the legal structure in which they are conducted, while ensuring at the same time that differences in business models and risk content are properly respected and reflected in regulation.

The G20 meeting on 14/15 October 2011 comes at a crucial time for the economy as well as for the regulatory reform process. Action is urgently required to restore business confidence by carefully striking a balance between supporting economic recovery, underpinning sustainable growth, and charting a credible path to fiscal and monetary stability as well as financial sector reform.

Full letter

© EFR - European Financial Services Round Table