FBE response on “supervisory tools for EU securities market“

01 February 2005

The European Banking Federation (FBE) released its response the so-called Himalaya report stating that the focus for CESR at this stage must be on making the best use of the current structure, rather than introducing new tools which do not have a sound basis in the current system of cooperation among national regulators. Before any changes to the current structure are introduced all tools available under the current structure should be exploited.

As any revision of the structure will involve an intense political discussion, FBE notes that the questions raised by CESR about the future are a useful starting point of collective reflection and debate.

However, FBE believes that CESR needs to deepen its “coordinator of supervisors” role, which is linked with the Lamfalussy Process, as it describes the current structure, whereby the idea of “supervisor of supervisors” introduced in the Paper falls into the category of what might be considered in the future. Therefore, the FBE recommends that CESR looks closely to the work of CEBS in developing the Consolidated Supervisor Model under the CRD.

Finally, all of the current directives in the FSAP which use the Lamfalussy Process have been designed with the current structure in mind. Any deviation from the basic structure would also require a major re-writing of these Directives.

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