Consultation on Green Paper (Com(2005)177)

01 August 2005

Graham Bishop's Comments
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SummaryConclusion: a Golden Opportunity • The Green Paper (GP) is right to stress the political orientation of acting in ways that ensure societal legitimacy. The new Impact Assessment Guidelines offer a sound approach to achieving the necessary rigour, but there are inherent limitations in the process. In part, these are logical and stem from the nature of the legislative process. If any Member States have solved these problems decisively, then the EU could learn from them. • But the Green Paper does not address the inadequacies of EU financial data – a prerequisite for convincing and thorough impact assessments (IA). The current moves to harmonise reporting requirements for some financial institutions offer a golden opportunity to correct this and, more importantly, lay the necessary foundations for a lead regulator for cross-border financial activities.

Contents
Political Orientation Evidence-based Legislation Methodology for the Impact Assessment Qualitative Quantitative Difficulties inherent in Impact Assessments Ex-ante analysis Ex-post analysis Appendix

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© Graham Bishop