FBE response to Commission’s Working Document on Capital Requirements

10 February 2003

The European Banking Federation (FBE) is among others concerned about the impact of the consolidation requirements proposed by the Commission, which are super-equivalent to the Basel Accord and raise practical concerns. Introducing more restrictive requirements at individual entity, as opposed to group level, will disadvantage EU institutions. In the FBE’s view, the Commission has yet to make its case justifying why this should be so.

The FBE’s response sets out the strategic objectives for the legislative framework. In summary, the framework should set common minimum standards and must:

apply to all credit institutions and investment firms, including niche competitors;

be based on the overarching principle that the same risks must be treated in the same way;

be proportionate and practical in terms of application to the financial sector;

avoid creating barriers to entry for small competitors and must not create permanent competitive distortions;

generate pressure to safeguard the Single Market by limiting the scope and reducing to a strict minimum the number of national discretions;

ensure an international level playing field for European banks.

FBE response

© FBE