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The consultation document outlined the problems that continue to affect the EU banking sector and outlined the potential contribution structural reform could make in addressing those problems. Stakeholders were then asked whether structural reform of the largest and most complex banking groups could address and alleviate these problems.
The consultation document then highlighted the on-going reforms within Member States and outlined the potential benefits of action at the EU level, that is, to preserve the integrity of the internal market. It then asked for stakeholders’ views on whether they considered an EU proposal in the field of structural reform necessary.
The remainder of the consultation document asked for views of stakeholders on the three different elements of bank structural reform: the scope of banks to be subject to potential separation, the activities to be separated, and the strength of separation. It also asked for stakeholders’ views on the best combination of activities and strength.
Bank responses are divided between those who argue against separation, and those who argue that if there is to be separation, then it should only focus on proprietary trading. This sentiment is echoed by corporates, who argue in favour of an as narrow separation as possible in order not to affect their access to (low cost) financial services. Individuals and consumer associations on the other hand favour option 3, i.e. separation of all investment bank activities.
While consumers are overwhelmingly in favour of the proposal for structural reform and banks are predominantly against, where respondents addressed the numerous detailed choices within the proposal, they displayed a wide range of views. Of course especially for the final policy option and the divide between banks and consumers regarding supervisory discretion, some dominant choices appear. Accompanied by several detailed, analytical responses to the consultation document, as well as the quantitative feedback from banks, the Commission has gleaned much information from the varied group of respondents.