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The Coalition, which represents a large part of the transatlantic financial services community, has been brought together by a strong and shared belief on both sides of the Atlantic that improving regulatory cooperation between the U.S. and EU must be a priority. It believes that a comprehensive Transatlantic Trade and Investment Partnership (TTIP) that includes both market‐opening measures and a framework for regulatory coherence in financial services is the best way of achieving this.
Noting that the most pressing impediments to cross border finance between U.S. and EU capital markets are the result of insufficient regulatory cooperation, the Coalition has also identified three important principles for delivering regulatory coherence that any successful regulatory dialogue should include and which TTIP should recognize: a focus on discussion at an early stage in the policymaking process, a focus exclusively on future policymaking and regulatory development, and a focus on transparency and accountability.
While the Coalition welcomes ongoing efforts to strengthen the EU‐U.S. Financial Markets Regulatory Dialogue (FMRD), it believes those efforts alone cannot deliver the benefits arising from a joint commitment to an agreed framework within TTIP. The Coalition believes TTIP is the best route to delivering regulatory coherence because it provides a unique opportunity to create a strong structure for a regulatory dialogue to ensure that regulators focus on cross‐border issues as they are developing, heading off conflicts or unnecessary differences that could be avoided.
A robust regulatory dialogue between regulators in the U.S. and EU, carried out under clear requirements agreed within TTIP by the respective financial supervisors, would reduce conflict and complexity and improve the efficiency of cross border regulations to the benefit of financial services providers and their regulators and – most importantly ‐ their end‐users in industry and commerce in the transatlantic marketplace. Moreover, TTIP is intended by both the EU and U.S. to strengthen cross‐border regulation while posing no threat to existing domestic rules and standards.