TAILIEUCHUNG - ESBG common response to the European Commission consultation on the Liikanen Report recommendations

To illustrate why the ring-fencing of market making activities would be that detrimental an example can be provided: Since the Liikanen Report does not recommend including underwriting within the ring-fence, commercial banks could still engage in these activities. Nevertheless, if these banks were to go to the secondary market to place these securities, then this activity would be considered as market making and therefore would be included in the ring-fencing scope. This will surely entail additional interests for the companies that demand these underwriting services due to the separation and the additional costs stemming from a more expensive funding. The. | POSITION PAPER ESBG common response to the European Commission consultation on the Liikanen Report recommendations. WSBI-ESBG World Institute of Savings Banks - European Savings Banks Group Rue Marie-Thérèse 11 - B-1000 Brussels WSBI-ESBG Register ID 8765978796-80 November 2012 Doc 1182 2012 First of all the European Savings Banks Group ESBG welcomes the opportunity to share its views and opinions on the Report provided by the High-level Expert Group on banking reform chaired by Mr. Liikanen the Liikanen Group . I. General observations The ESBG appreciates the efforts of the European Commission and the Liikanen Group to strengthen financial stability in the European banking landscape. The ESBG also welcomes the fact that the Liikanen Group brings the risky practices of investment banking including proprietary trading shadow banking and the Too big to fail-Problem to the spotlight leaving aside the Vickers Report approach. In this sense we appreciate that these proposals do not include any increase in capital requirements for retail banks and do not envisage a separation of businesses for the entire banking system - in particular for the small savings and retail banks. Nevertheless a first assessment of the report leads us to reiterate our doubts about the need for further regulatory reforms for the banking industry. The ESBG is of the opinion that there is an excess of financial regulation taking place that might result in an excessive and inflexible regulation and in many cases will lead to overlaps between the different regulations as well as unintentional consequences. The Liikanen Group s proposals aim to tackle some of the problems that have been addressed by different regulation proposals such as CRD IV the Crisis Management proposal Governance and the DGS Review. Given that many of these regulatory reforms which are of considerable impact are still under discussion and their final outcomes are not yet certain we consider that it has not been appropriate to .

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