REPORT on stocktaking and challenges of the EU Financial Services Regulation: impact and the way forward towards a more efficient and effective EU framework for Financial Regulation and a Capital Markets Union

Firstly I would like to thank Burkhard Balz for all of his hard work on this file.

Over the past five years, the EU has put in place an unprecedented amount of new financial services legislation ,therefore it is right that we take a step back and look at the overlaps and cross overs at this time.

Mr Balz’s report clearly emphasises that this review needs to go beyond value judgements and qualitative statements but any meaningful review should have a strongly quantitative aspect to it.

For me the key areas of this report refer to the overlaps between files – particularly the cross over between MiFID and CRD4 where we have brought new firms into markets legislation without tailoring the capital standards to suit these new types of firms.

A similar issue of scope is seen with the clearing obligation in EMIR the arrangements for non-financial firms that were intended to prevent financial firms misusing a justified exemption have led to huge amounts of red tape for businesses that were never meant to be included.

I hope the Commission is working on solutions via the formal consultation and review or where possible reissuing level 2 standards to solve these issues to give practical weight to their promises around the Better regulation agenda.