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In a letter to the United States Federal Reserve (18 April 2013), EBF Chief Executive Guido Ravoet said the new rules discriminate against European banks doing business in the US, as foreign banks would have to allocate capital and liquidity according to US requirements regardless of their home-country rules.
The EBF says that the US plans to force foreign banking organisations into so-called Intermediate Holding Companies would put Europe’s banks at a distinct disadvantage and would not help in the creation of a global level playing field and further, would not in the long term contribute to the process of global economic recovery.
Finally, EU banks note that the proposed regulations mark a distinct change from established policy where US authorities have allowed the capital requirements of branches of foreign banks to be mainly supervised by their home countries and the capital strength of a consolidated group to be taken into account.
The EBF comments concur with a recent letter written by Internal Market and Services Commissioner Michel Barnier, asking US Federal Reserve Chairman Ben Bernanke to allow for deference of home country regulation where this is equivalent to that of the US.