AFME commented on the EBA consultation paper on draft ITS on passport notifications under articles 35, 36 and 39 of the proposed Capital Requirements Directive.
AFME members support the EBA’s work on seeking to ensure coherence of the Technical Standards arising from these provisions and, in that light, developing a harmonised framework for passporting notifications. The proposals represent an important step in enhancing supervisory convergence, preventing regulatory arbitrage and achieving a level playing field for firms.
AFME agrees that it is helpful to use the existing Passport Guidelines developed by the Committee of European Banking Supervisors (CEBS) as the basis, given firms’ experience in utilising this framework. Overall AFME hopes that the common templates will result in a smoother and speedier flow of information between both firms and competent authorities. Members have highlighted that, under the previous regime, some firms experienced a lack of certainty regarding the assessment criteria for their application and the exact date on which they were in a position to commence activities in the host Member State so a more formalised protocol will be welcome.
AFME would hope that going forward and given the streamlining of information, competent authorities will be able to assess passporting applications even more quickly than the timelines mandated by the regulatory framework, with firms thus being able to provide services more quickly to the benefit of their clients.
AFME would like to discuss with the EBA the range of issues covered in this consultation also e.g. to include to communications between firms and host regulators, or to provide further information about any of the matters which its members have raised if that would be helpful.
Full consultation response
© AFME
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