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According to the ESBG, up-front judgments made by the Commission will create market uncertainty and delay adoption of the pan-European payment instruments. It is essential that the Commission reconciles its vision of SEPA with the project risk undertaken by the banking industry. Also, several statements in the Consultative Paper do not rest on solid ground yet may influence stakeholders’ responses to SEPA. Neither an impact assessment nor a cost benefit analysis comparing the costs and savings from SEPA has been produced by the Commission so far to provide a solid basis for such a statement.