ANNEX B: EXTRACT FROM THE CITY OF LONDON
CORPORATION'S RESPONSE OF 15 JULY 2009 TO THE COMMISSION COMMUNICATION
"EUROPEAN FINANCIAL SUPERVISION"
"Overview:
"1. We support the broad objectives set out
by the Commission: a more efficient framework for financial supervision,
enhanced financial stability, greater safeguards of the interests
of consumers and investors, increased competitiveness of EU financial
markets and more integration of EU financial markets.
"2. In creating the new structures, it is essential
that policy makers remain focused on the outcomes, such as better
and more consistent supervision. Key objectives must be to support
open markets, to increase competition by encouraging a level playing
field and to ensure as far as possible consistency of arrangements
globally, regionally and locally, recognising that so many EU
firms and markets, as well as their users, have a global presence.
"3. Before we set out our detailed commentary
and proposals for further developing the objectives of the Communication,
we wish to identify several areas where we believe further clarification
is required as the legislative proposals to bring effect to the
new structures are developed over the summer
"Clarification:
"4. It is essential to be clear on the distinction
between supervision and regulation. Regulation — the act
of agreeing and setting new rules, together with amending existing
regulation — should focus on delivering convergence towards
a consistent single rule book. Supervision on the other hand,
which involves the oversight of individual firms, must allow for
a (high) degree of professional judgement to understand the circumstances
of specific firms. That said, supervisors need to converge their
supervisory practices and ensure that like firms are treated similarly.
"5. In the case of "Disagreement between
national supervisors" (point 4.2 (2)) it will be important
to specify what sort of "diverging opinions" would be
covered. The scope of "Full supervisory powers for some specific
entities" (point 4.2 (4)) also needs clarification. More
fundamentally still is the definition and concept of "binding
cooperation" in relation to cooperation between the European
Systemic Risk Board and the European System of Financial Supervisors.
"6. We would also question whether it is appropriate
for representatives from the European Supervisory Authorities
to be present on supervisory colleges."
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