IIF Authors

Status: Will be live at 10/06/2015 00:00

IIF European Commission Consultation Response CRR/CRD IV

Tuesday, October 6, 2015

The IIF shares the European Commission's increased focus on this important area, and we welcome the exploration of downstream impacts as an important and worthwhile initiative. We commend the Commission's initiative, and hope this exercise could set a precedent for similar reviews in other sectors and for other jurisdictions.

In line with the IIF's international membership across multiple sectors, our response seeks to bring a perspective to this consultation that is both (i) global and (ii) extends beyond banking, noting that the effects of banking regulation on the wider economy can be magnified by the dynamics in other sectors. Concurrently, we have sought to concentrate our response to this Consultation on only those issues where the IIF can contribute some additive input, structuring our more targeted comments in two parts:

  • Firstly, to highlight four major themes that we feel warrant further consideration by the Commission and regulatory bodies.
  • Secondly, in three areas where the IIF has undertaken some preliminary research and analysis in support of these themes; these each tie to a subset of the specific questions posed in the Consultation.