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The Luxembourg Bankers’ Association (ABBL)
The ABBL would urge the European Commission to pay particular attention to proportionality that is better able to safeguard business practices and ensure efficient regulations. Lots of regulatory inconsistencies, constrains and impacts could have been avoided through more proportionality and differentiation. Member States direct and indirect gold plating through local rules should also be limited.
Furthermore, while the consultation of the Commission is welcomed and the objective of streamlining requirements and correcting inconsistencies is appreciated, one should alert European legislators of all other inconsistency risks. In that vein, it is important to underline that several requirements risk to conflict or be inconsistent with regard to global requirements, thus introducing a dose of systemic risks in the system. Therefore, the efforts undertaken by the European Commission relative to European Financial Regulations should also be undertaken on the global financial regulatory scene.
In its efforts to seat on global fora, the European Commission bearing the European specifies in mind should ensure that European rules are consistent with global standards whilst preserving economic opportunities. Examples of regulations affecting the financial sector being set up at the global levels are numerous: BEPS action plan and OECD standard of financial account information for the automatic exchange of financial account information, regulatory initiatives at the Basel Committee (Basel III ratio, etc.) Some rules are already triggering some difficulties and questions with regard to their implementation at the European level (e.g. Total Loss Absorbing Capacity (TLAC) vs. MREL, automatic exchange of financial account information).
European Banking Federation (EBF)
More than a year ago, President Juncker’s mandate started on a positive note, by establishing a long awaited motto: “I want to be big on big things, and small on small things”. The better regulation agenda, and then DG FISMA’s initiative opened the path for more concrete actions aiming at more coherence in the EU legislative framework.
The tremendous and swift joint efforts achieved from both regulator and financial industry sides, have been successful in fostering the resilience of the European banking sector.
The European Banking Federation (EBF) has always been supportive of these necessary developments and will continue to work with policymakers on the regulatory reform programme.
The EBF believes that it is now a good time for the European Commission to operate a revision of the regulatory framework in the area of banking regulation and supervision. More specifically, the focus on the interaction between the various reforms and their cumulative impact on banking activities is strongly welcomed with this call for evidence.
In this regard, we have tried in this response to focus on 55 issues, on which we sought to bring concrete and proactive solutions that would help to serve the real economy.