This summer the European Commission launched a new consultation on the“possible impact of the CRR and CRD IV on bank financing of the economy”, which raises a number of concerns. Indeed, the questions in the consultation document seem to focus too much on the alleged constraints on banks’ ability to lend and the implementation costs, rather than on the benefits of the regulation for the economy and for society at large. Given the usual imbalance in the responses (in favour of the financial industry), the compilation of responses to the consultation could result in a perception that the cost of implementing some provisions of the CRD package (a private cost) outweighs the cost of not implementing them (a social cost). The outcome of the consultation could therefore put pressure on policy makers to decrease standards rather than deliver a (much-needed) improvement, which would be a poor outcome from a public interest perspective.
What can I do?
All organisations and citizens are able to contribute to this consultation. The deadline is 7 October. Here is how to do it:
- The online questionnaire of the consultation and related documents and information are available on the European Commission’s website here: https://ec.europa.eu/eusurvey/runner/long-term-finance-2015?surveylanguage=en
- Questions include multiple choice and free text boxes. Choose which questions you want to answer (we suggest focussing on questions 2, 4, 5, 9, 13, 14, 15) and fill-in the online questionnaire: the first part is to provide key information about you or your organisation; the second part (“your opinion”) is where you can make your points.
- If you wish, you can use the answers suggested by Finance Watch in the second page of this document (click here to download it) (2)
Responses will be published on the Commission’s website and analysed once the consultation is closed. Finance Watch plans to comment on the outcome of the consultation. To follow our work, subscribe to our newsletter here: http://www.finance-watch.org/friends-newsletter
(1) To know more, see Finance Watch’s assessment of the EU regulation on the capital of banks here : http://www.finance-watch.org/our-work/dossiers?fid=94
(2) For background on some of the issues raised, see our paper “Basel 3 in 5 Questions” http://www.finance-watch.org/ifile/Publications/Reports/Basel-3-in-5-questions.pdf . For a debunk of arguments commonly used against higher capital, see http://bankersnewclothes.com/wp-content/uploads/2014/10/Parade-continues-October.pdf