- In its response to a consultation by the European Commission, the German Banking Industry Committee (GBIC) criticises “unnecessary burdens” arising from new banking regulation. The costs generated by implementing the regulatory requirements pose a significant challenge, especially for small banks. GBIC is highly critical of the excessively short periods granted to implement many regulatory requirements.
Individual regulatory measures may seem appropriate when looked at in isolation. Collectively, however, their sheer number and their interaction with one another mean that they go too far. They threaten to overburden both banks and supervisors.
Commenting on the European Commission’s “Call for Evidence: EU Regulatory Framework for Financial Services”, GBIC bemoans the lack of a proportional approach in many regulatory requirements. Such an approach is necessary to avoid placing too great a strain on smaller banks. GBIC consequently welcomes recent proposals to review all new legislation to make sure it is sufficiently proportionate.
The Commission’s consultation provides a good basis for analysing and improving legislation. GBIC therefore calls for European financial regulation to be checked at regular intervals for contradictory rules and unnecessary burdens. Two examples of excessive regulatory burdens at present are unduly bureaucratic investor protection and an unwieldy reporting regime.
GBIC is also critical of the timetables for implementing new regulatory requirements. These are often far too tight, which significantly increases the complexity and workload involved in implementation because legally binding regulations are either not published in time or only published just before the first reporting date.
Regulation of banks and financial markets should also consider the banking industry’s competitiveness and ability to function.