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31 January 2016

ABBL’s and EBF’s answer to the EU Commission “Call for Evidence on EU Regulatory Framework for Financial Services”

The ABBL and EBF have delivered their responses to EU call for evidence identifying 55 issues that need addressing. EBF's Wim Mijs said “Now is a natural moment for calibration.”

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.


© ABBL - Luxembourg Bankers’ Association

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