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The EBF calls for closer co-operation and convergence of European supervisory bodies. A key aspect could be to grant 3L3 Committees an increased visibility at the European level, EBF states. Commenting on the Council Roadmap on the Lamfalussy Process, “an explicit reference in the EU legislation of the 3L3 and their role, and a regular assessment of their performance by the EU Institutions would be a first step in that direction”, EBF states.
The EBF is particularly concerned about the lack of a Level 1 framework directive with regard to the CRD. As the CRD is not a Lamfalussy directive, “the national transposition process has resulted in technical ambiguities and many national discretions, some of which have the potential to significantly undermine the creation of a single level playing field in Europe”, EFB states.
“The difficulties to deliver a truly Common Reporting format for banking supervision leads to unduly costly for financial institutions to operate across borders”, FBE says. “We also fear that such a situation hinders the realisation of the EU financial market’s integration”,
“We continue to witness a degree of inertia in respect of the elimination of national discretions in this area and the consequent destabilising effect they have on the ability of banks to carry out business efficiently across Europe”, FBE notes and calls for better coordination between Levels 1 and 2.
The Federation underlines that greater convergence of rules and practices would also facilitate an effective coordination between national supervisory authorities, Finance Ministries and Central Banks in crises prevention and resolution.