Publication date: 12 April 2018

The European Banking Federation fully supports the European Commission’s intention to consult with stakeholders about the potential impact of the finalisation of Basel III and on the implementation challenges involved.

The Commission’s clarity about the order of the legislative packages adds transparency to the process and is appreciated by the industry. It is reassuring that any legislative proposal to implement the outstanding Basel III reforms would be independent from the Risk Reduction Measures package currently under negotiation by the European Parliament and the Council. We would like to avail of this opportunity to remind the Commission that the Fundamental Review of the Trading Book (FRTB) has been placed in the same timeline as the finalisation of Basel III, therefore, it should be aligned accordingly.

Nevertheless, we have been surprised about the extremely short timeline for consultation. As stated in the EBF letter to Vice-President Dombrovskis, sent on 19 March 2018, these proposals will have long term effects on the EU banking system and the EU economy. They would therefore deserve a normal period for consultation ranging from two to three months. Interested parties should be given sufficient time to conduct analyses from their respective viewpoints if the Commission aims at receiving well-informed assessments. In particular, the Commission requests evidence on the potential impacts of those reforms on the EU banking sector and the wider economy. This cannot possibly be done in a few days.

In view of this situation, the present response of the EBF on behalf of the European banking industry, cannot be considered as comprehensive. It merely indicates a non-exhaustive list of areas that would deserve further analysis before a legislative proposal is devised. Given the above-mentioned insufficient time for proper consultation, the EBF may probably raise further relevant issues or develop more in-depth the matters presented in this document. We look forward to a long and deep engagement on this dossier.