FIN-USE. Providing expertise for policymakers. July FIN-USE, c/o European Commission SPA2 4/69, BE-1049 Brussels

Transcription

1 EXPERT FORUM OF FINANCIAL SERVICES USERS Providing expertise for policymakers RESPONSE TO THE COMMISSION S COMMUNICATION ON EUROPEAN FINANCIAL SUPERVISION July 2009, c/o European Commission SPA2 4/69, BE-1049 Brussels Telephone: (32-2) Telephone: direct line (32-2) Fax: (32-2)

2 INTRODUCTION welcomes the opportunity to submit a response to this important Communication from the Commission. is of the view that a financial system can only be judged a success if it is stable and sound, competitive and efficient, well-governed and accountable to society, fair and inclusive, and produces socially useful innovations. The ongoing financial crisis has serious consequences for millions of citizens in the European Union. The behaviour of poorly governed and regulated financial markets and financial institutions has put at risk the savings, investments, pensions, jobs, and financial security of millions of EU citizens. Moreover, the serious, chronic problem of financial exclusion in the EU is set to deteriorate even further as financial institutions restrict access to affordable financial products and services to higher income, lower risk consumers. Set against those measures, it is clear that radical, far-reaching reforms to the EU s financial markets and financial institutions are needed if the needs of citizens and society are to be met effectively and sustainably. Reform is needed throughout the entire financial system. This means reforming the regulatory architecture and approach to regulation at international, EU and member state level so that: the financial system is stable (macro-prudential regulation); individual financial institutions are sound (micro-prudential regulation); financial markets and institutions operate to the highest standards of corporate governance, accountability and transparency; the financial services industry treats users fairly and markets are competitive and efficient (retail/ consumer protection regulation). Although this Communication is limited to proposals for a new regulatory architecture for macro- and micro- prudential regulation (which we support), we believe there are there other important issues to address if we are to deliver the necessary reforms. Therefore, we have taken this opportunity to comment on those issues even if they were not included in the Communication. Therefore, our submission is structured as follows: summary of position; user voice in the EU; specific views on the proposals for a European Systemic Risk Council (ESRC) and European System of Financial Supervisors (ESFS); the need for a new European Financial Users Authority (EFUA); consumer and investor protection legislation. Response to the Commission s Communication on European Financial Supervision 1

3 SUMMARY OF POSITION welcomes the publication of the Communication on European Financial Supervision and the determination of the Commission to implement the programme of reforms. As we set out below, we support the key proposals relating to macro- and micro- prudential regulatory reforms. These issues are very important and we recognise why the Commission has focused on them. But we are very concerned that the Communication contains no proposals for improving corporate governance or consumer/ investor protection regulation. It may well be that this Communication was intended to focus on the narrow issues of macro- and micro- prudential regulation and the Commission will give the same priority to these other critical issues in separate initiatives. We certainly hope so. Moreover, this Communication deals with the architecture of regulation. It does not address the approach to regulation to be adopted by the new EU regulatory institutions and national supervisors. If the financial market reforms are to be effective, regulators and supervisors must adopt a much more robust and interventionist approach to financial regulation, risk management and enforcement. We presume that the Commission and relevant supervisory authorities will be consulting on the new approach separately. has set out its vision for a new approach to financial regulation in its recent opinion on financial services supervision 1. We welcome the proposed regulatory architecture consisting of a European Systemic Risk Council (ESRC) and European System of Financial Supervisors (ESFS). This is very similar to the architecture proposed in its response to the consultation on the Future of Financial Services Supervision 2. However, we have a number of concerns about the specific proposals in the Communication. These proposals are very much based on the recommendations in the De Larosiere report, which was generally positive but had some very obvious and serious deficiencies that have been carried over into the Communication. Critically, De Larosiere did not seem to recognise the need to improve regulatory accountability and user representation within policy making structures. As we set out in our position paper on Consumer Voice in Financial Services 3, ensuring that users views are embedded in the development of products and regulation is fundamental if the market is to operate fairly, orderly and efficiently. Moreover, proper user representation within the policy making process will be important to restore citizen s confidence in the financial system and ongoing financial market reforms Response to the Commission s Communication on European Financial Supervision 2

4 Unfortunately, this recent Communication appears to ignore regulatory governance and user representation and makes only a passing reference to liaising with relevant stakeholders (including consumers) in a structured way. We urge the Commission to rectify this omission as a priority and publish concrete plans for ensuring that the user interest is represented properly within the new regulatory institutions. We have included a number of proposals for improving user representation and would be happy to engage with the Commission on developing these proposals. We support the creation of the ESRC and ESFS to promote more consistent, coherent and effective macro- and micro- prudential regulation, and we are impressed at the way the Commission has been able to produce an accelerated reform programme. However, we are very surprised and concerned that the Commission has not followed through this logic and recognised the need to create a similar structure to ensure more consistent, coherent and robust retail regulation/ consumer and investor protection measures. We argue that there is equal, if not greater, need for improved consumer and investor protection regulation. Therefore, we recommend that the Commission prioritise a study into establishing of a European Financial Users Authority to undertake this role. In addition, De Larosiere did not seem to properly recognise the role long term investors (such as pension funds trustees) and failure of corporate governance in financial institutions played in the financial crisis. The Communication also seems to ignore this critical issue. A series of measures are needed to improve financial governance and ensure that ordinary citizen-investors and their representatives (such as pension fund trustees) are able to exercise due diligence and responsible influence over the behaviour of financial institutions. We do not include detailed recommendations in this response as these can be found in our opinion The Future of Financial Services Supervision 4. However, we would welcome a response from the Commission on its plans for improving corporate governance and increasing the influence of citizen-investors. Our final concern relates to the timetable for other regulatory reform initiatives. We are pleased that the Commission is undertaking a series of initiatives intended to improve consumer/ investor protection. These include initiatives relating to issues such as: packaged retail investment products; responsible lending; and promoting financial inclusion. However, we are extremely concerned that these consumer protection initiatives are not being given the same priority as the macro- and micro- prudential regulatory reforms. The Commission has demonstrated an impressive capacity for accelerating extremely complex macro- and micro- regulatory reforms and plans to have the new supervisory framework in place by end It is self-evident that the Commission has the capacity to apply the same urgency to consumer/ investor protection reforms and we urge it do so to protect users in the EU. 4 Response to the Commission s Communication on European Financial Supervision 3

5 USER REPRESENTATION IN THE EU It is clear that the Commission has given a great deal of thought into the governance of the new regulatory institutions. However, is very surprised and disappointed that the Communication makes no concrete proposals at this stage for ensuring that the user voice is represented within the new structure and institutions. The only reference to user representation is a statement that The European Supervisory Authorities should liaise in a structured way with all relevant stakeholders, including consumers. We do not think this position is sustainable. As we explained in our paper Consumer Voice, the existing user representation mechanisms associated with the level 3 committees (CEBS, CEIOPS, CESR) are insufficient. Each of the three level 3 committees has a consultative panel. Overall, of the 55 members on the three consultative panels, only five have a user representative background 5. concluded that up to now within the decision making process at EU and member state level: users have very little opportunity to influence the work of the level 3 committees which play such an important role in policy formulation and regulation on financial services; this compounds the serious lack of consumer/ user representation at national level and lack of resources available to user/ consumer representatives; industry lobbies are over-represented. This must give the industry undue influence during the process of formulating, developing and implementing policy and introduce conflicts of interest on the regulators boards; and the level of under-representation is unacceptable and cannot be continued in the new regime that replaces the existing regulatory structure. Comprehensive, new measures are needed to improve consumer/ user representation at national and EU level. Therefore, in light of this weak regulatory governance and serious lack of accountability representation, we had high expectations that the Commission would recognise the wisdom of ensuring that the user voice was heard by publishing new proposals for user representation mechanisms alongside the proposals for regulatory reform. It must be recognised that, as a fundamental issue of principle, there is simply no justification for financial regulators and policy makers failing to ensure there are meaningful user representation at the highest decision making level given the importance of financial markets to society. Moreover, we believe the quality of decision making by regulators and policymakers would improve if it was subject to direct scrutiny by user 5 We based this research on information listed on the consultative panels websites. Response to the Commission s Communication on European Financial Supervision 4

6 representatives who would have the independence and objectivity to challenge market and regulatory orthodoxy. Furthermore, a commitment to user representation promotes confidence in the system and allows policymakers and regulators to avoid the perceived risk of regulatory capture by powerful industry lobbies. We hope that the Commission will address this omission and introduce the appropriate user representation mechanisms. Therefore, has made a number of recommendations to improve governance and representation at EU and member state level. RECOMMENDATIONS ON GOVERNANCE AND REPRESENTATION EU level We expect that, at the very least, the existing consultative panel structure will be maintained to ensure user representatives have direct input into the work of the new supervisory authorities. However, the consultative panel structure, in and of itself, is no substitute for proper user representation at each level of the new regulatory structure: the Steering Committee; Board of Supervisors of each Supervisory Authority; and Supervisory Authority Consultative Panel. High level governance and accountability Recommendation 1: to promote good governance and user confidence, a minimum number of seats on the Steering Committee should be reserved for user representatives. The board should also have a minimum number of seats reserved for emerging EU economies. Recommendation 2: similarly, a minimum number of seats on the Supervisory Boards of the EBA, EIOPA, and ESA should be reserved for user representatives. Supervisory authority consultative panels Recommendation 3: each of the new supervisory authorities should have a consultative panel along the lines of the existing level 3 consultative panels. Recommendation 4: each supervisory authority should ensure that at least onethird of the consultative panels are user representatives, and that these userrepresentatives should have sufficient resources to undertake their role effectively. Recommendation 5: each supervisory authority consultative panel should establish a consumer/ user expert group. The role of the expert group should be to: provide specialist insight to supervisory authorities regarding the impact of consultations and initiatives on consumers/ users, and ensure the decision making process takes consumer/ user interests into account. Response to the Commission s Communication on European Financial Supervision 5

7 Recommendation 6: each committee should appoint a consumer coordinator to support the work of the consumer/ expert standing committee and coordinate relationships with consumer/ user organisations. Capacity building Recommendation 7: the EC should properly resource as its user expert forum. Recommendation 8: the EC should help fund the representation of financial services users at the European level, to address the huge imbalance of resources between users and the financial industries in terms of European lobbying, and enable financial users to make their voice heard at the European level. Member state level The previous set of recommendations relate to the governance and accountability within the EU regulatory process. However, if the new coordinated system of regulation is to work efficiently, we believe that regulation must be more effective at member state level. This set of recommendations is intended to allow user/ consumer representatives to have greater influence over the policymaking process, and enables citizens to hold regulators to account. We urge the Commission to use its influence to develop best practice on consumer representation in the EU and ensure that governance and representation in member states is improved. Recommendation 1: National laws governing national financial regulators should clearly state that one key objective of such regulators is to protect the financial services users. Recommendation 2: the relevant government department in member states should ensure that at least one-third of the governing boards of each of the main financial regulators in their jurisdiction are users/ consumers/ public interest representatives. No more than one-third of the board members should be from the financial services industry or with this recent background. Recommendation 3: the regulators should ensure that the user/ consumer / public interest representatives on the governing boards have access to dedicated, independent technical expertise and sufficient resources to support their role (for example, to ensure they have access to resources through an independent consumer panel see below). Members of the board who are not compensated by another employer should be compensated for these responsibilities and work. Recommendation 4: with regards to appointments to governing boards, consumer/ user groups should have the right to nominate candidates to national governments. Moreover, any appointments panel overseeing the appointment of individuals to the main board of regulators should normally contain representatives nominated by user/ consumer groups. Response to the Commission s Communication on European Financial Supervision 6

8 Recommendation 5: financial regulators should be required to establish an independent consumer/ user panel to advise on policy formulation. The panel should be consulted at the earliest possible stage on changes of policy and prioritisation of regulators activities and have access to any complaints data. To support the panel it is important that it should have access to a dedicated, independent source of technical expertise. The panel should have its own research capacity including financial resources to undertake independent research and employ dedicated research staff. Budgets need to be agreed with government and user/consumer representatives. The sufficiency of the budget needs to be periodically reviewed. Panel members who are not employed and compensated by another institution should be compensated. Recommendation 6: the consumer panel should be required to produce an annual report setting out its activities for the previous year, an assessment of the performance by the regulator of its duties, and recommendations for the coming year. The financial regulator should be required to respond to the panel s report justifying where appropriate why the panel s recommendations have not been adopted. Recommendation 7: financial regulators should be required to attend two public hearings each year following publication of the annual report. Both the financial regulators and independent panel should be required to present their annual reports and answer questions put to them by the committees conducting the hearings. The first public hearing should be conducted with elected representatives this would be similar to the UK Treasury Select Committees or Senate Hearings in the USA. The second hearing should be conducted with public interest representatives. Recommendation 8: governments and regulators should adopt a new, transparent approach to disclosing information relating to corporate behaviour and regulator s enforcement decisions. Regulators should introduce a new rule (if it does not exist) that requires financial firms to publish key consumer information that might affect a consumer s decision to enter or continue a relationship with the firm. The categories of information should include: consumer complaints data; decisions by financial ombudsman schemes; policies and procedures; and details of regulatory breaches along with summaries of action taken to address problems. Firms should also be required to produce compliance reports once a year providing a detailed assessment of performance against regulatory requirements. Recommendation 9: the European Commission, national governments and regulators should review any legislation that prevents information being published in the public interest. The default position should be that the public interest and consumer interest should take precedence over narrow commercial interests. The presumption should be that all information should be disclosed unless it is clearly demonstrated that disclosing information is not in the public interest6. Holding regulators and firms to account for performance depends on user/ consumer representatives having access to information. 6 For example, if it was clear that disclosure would jeopardise enforcement proceedings, or if disclosure of trading positions would leave firms vulnerable to attacks by rivals. Response to the Commission s Communication on European Financial Supervision 7

9 Recommendation 10: Proposed new regulation needs to be subject to impact assessment taking into account both the cost and benefits of its implementation. The assessments must be transparent as to the factors that have been considered in the analysis. Recommendation 11: All members of national regulator boards and users panel members should write and disclose a conflicts of interests statement prior to their appointment, as the EC requires from members. SPECIFIC VIEWS ON THE PROPOSALS IN THE COMMUNICATION The nature of modern financial markets means that a narrow, national approach to financial market regulation is not effective. The work of macro-prudential and micro-prudential regulators and supervisors needs to be coordinated to be effective. There is a strong case for combining the macro and micro-prudential functions within the same organisational structure given the need for cooperation. However, we believe there is a stronger case for separating macro and micro regulatory institutions, primarily in the interests of clarity and efficiency. Therefore, we support the proposal to establish a European Systemic Risk Council (ESRC) and European System of Financial Supervisors (ESFS). The European Systemic Risk Council (ESRC) supports the creation of the ESRC which would be responsible for safeguarding financial stability by conducting macro-prudential supervision at the European level. We take the view that such an organisation is needed to improve the regulation of the financial system. This is similar to the proposal has already made for a EU level Financial Stability Agency to: promote financial stability at EU level; monitor risk at EU level; reduce the risk of systemic crises recurring; and coordinate responses to systemic crises. The proposals are similar to the proposed role and duties the Commission is proposing for the ESRC set out in paragraph 3.2 of the Communication. In s views, a critical priority here will be to find appropriate mechanisms to ensure that: precise and independent analyses and risk warnings can be prepared; Response to the Commission s Communication on European Financial Supervision 8

10 analyses and warnings can be transformed into effective policy responses - particularly since correcting measures will have to be implemented at national level. To further strengthen the effectiveness of the ESRC, its operations should be subject to a high degree of transparency, preferably by public disclosure of analyses and recommendations. However, we must express our concerns about the proposed governance measures set out in the Communication (see para 3.3, page 7) in particular the absence of clear, dedicated user representation measures. The Commission is proposing that the ESRC would include the central bank governors of the 27 Member States, the President of the ECB (who would be Chair of the ESRC), Chairs of the three European Supervisory Authorities (see below), and a member of the European Commission. A representative of the national supervisory authorities accompanying the central bank Governor in a 1-1 formula and Chair of the EFC would attend as observers. In addition, the Commission is proposing the establishment of a small steering committee to prepare and ensure efficient ESRC meetings. This steering committee would consist of the ESRC chairperson and vice-chairperson, five additional central bank members of the ESRC, the chairpersons of the new European Supervisory Authorities and the Commission member. Furthermore, an advisory technical committee is proposed to support the ESRC, including preparing detailed technical analysis of financial stability issues. The ECB will provide the Secretariat to the ESRC as well as analytical, administrative and logistic support. The Commission states that, in performing its duties, it would seem advisable that the ESRC should also seek the advice of private-sector stakeholders, including consumer representatives. While we welcome the recognition given to the desirability of seeking the advice of user-representatives, this is no substitute for meaningful user representation within the ESRC structures. Therefore, we believe that to promote good governance and user confidence it is critical that a minimum number of seats on the governing board of the ESRC should be reserved for user representatives. The board should also reflect the changing nature of the EU economy with a minimum number of seats reserved for emerging EU economies. European System of Financial Supervisors (ESFS) As well as improving macro-prudential regulation and systemic risk management, radical reform to the way individual financial institutions are regulated and supervised is equally important to restore confidence, protect consumers, promote financial stability and, critically, prevent regulatory arbitrage. Financial markets can be vulnerable to group behaviour. Financial Response to the Commission s Communication on European Financial Supervision 9

11 contagion can spread risk and the reckless behaviour of a handful of irresponsible financial institutions can trigger systemic crises. Macro-prudential regulation needs to be put into effect through microprudential rules that control the behaviour of financial institutions, and set minimum standards to avoid regulatory arbitrage. Therefore, we strongly support the proposal to establish a ESFS. This is very much in line with the proposals set out for the establishment of a European Financial Regulatory Authority. s view is that the key functions and activities of ESFS should be to: coordinate and establish prudential standards for all financial institutions including banks, insurance companies, and hedge funds, and financial instruments such as securitised investment vehicles; oversee the monitoring of EU financial institutions; identify systemic risks caused by behaviour of financial institutions; issue risk warnings and guidance to national micro-prudential supervisors; coordinate relationships between the relevant national micro-prudential supervisors; coordinate working relationships with macro-prudential and microprudential regulators; coordinate responses to financial crisis with ESRC. To be effective, and to prevent regulatory arbitrage, the ESFS should have authority to set appropriate EU wide regulations and standards for financial institutions. The actual supervision of financial institutions and enforcement of regulations should be the responsibility of national supervisory authorities. However, as above with the ESRC a critical priority will be to find appropriate mechanisms to ensure that: 1) precise and independent analyses and risk warnings can be prepared; and 2) these analyses and warnings can be transformed into effective policy responses. Particularly complicating is the fact that warnings and recommendations will be decided at EU-level while correcting measures will have to be implemented (mostly) at national level. To be able to undertake sharp analyses, warning and recommendations on basis of an EU-wide mandate the ESFS needs be sufficiently independent, as well as have an appropriate decision making structure. To further strengthen the compliance mechanism the work of ESFS should be subject to a high degree of transparency, preferably by public disclosure of analyses and recommendations. We also support the establishment of the three Supervisory Authorities the European Banking Authority (EBA); European Insurance and Occupational Response to the Commission s Communication on European Financial Supervision 10

12 Pensions Authority (EIOPA); and European Securities Authority (ESA). These new authorities would replace the existing level 3 committees CEBS, CEIOPS, and CESR. However, as above, we are very concerned about the governance proposals and the absence of concrete, meaningful mechanisms for ensuring the user interest is represented within the new structures. We are encouraged that the European Supervisory Authorities would be fully accountable to the Council, the European Parliament and the Commission. We have few details to judge how the authorities would be held accountable with the exception of the requirement that they would have to report formally to the European Institutions on a frequent basis (e.g., at least bi-annually). To improve governance and accountability, we take the view that at the same time as the publication of their formal bi-annual reports, the three supervisory authorities should be required to take part in two public hearings. The purpose of these public hearings would be to allow public interest representatives to question and challenge the supervisory authorities on their activities over the relevant period. The first public hearing should be conducted with elected representatives in the Parliament. The second hearing should be conducted with a committee of public interest representatives. Moreover, we have a number of concerns about the proposed governance arrangements for the new supervisory authorities. The intention is that each new Authority would have a Board of Supervisors comprised of the highest-level representatives from the appropriate national supervisory authorities and chaired by the chairperson of the respective European Supervisory Authority. Representatives from the Commission, the ESRC and the relevant supervisory authorities from EFTA-EEA countries would take part in the Board of Supervisors as observers. A Management Board would also be set up to deal with general operational issues (such as the budget) and would include the Commission. The chairpersons and secretary generals of the European Supervisory Authorities would be full-time independent professionals. The chairperson will be nominated after an open competition. Appointment would be confirmed by the European Parliament and should be valid for a period of 5 years. The intention is that the European Supervisory Authorities decisions on technical rules would be taken, through the board structure, by qualified majority based on the Treaty weighting for Member States. Separate arrangements should be considered for dealing with other functions of the European Supervisory Authorities. For example, decisions on the application of existing laws should be taken by simple majority on the basis of "one person, one vote". This may be an effective way forward but much more clarity is needed for the scope of simple majority and qualified majority based on the treaty weighting for Member States before a final assessment of the appropriate governance structures can be made. Response to the Commission s Communication on European Financial Supervision 11

13 THE NEED FOR A EUROPEAN FINANCIAL USERS AUTHORITY (EFUA) We are confident that the recommendations on governance and representation set out above would contribute to the development of more effective regulation and supervision by the new regulatory institutions. We also very much support the creation of the ESRC and ESFS to promote more consistent, coherent and effective macro- and micro- prudential regulation, and we are impressed at the way the Commission has been able to produce an accelerated reform programme. The Commission rightly recognises the need to establish new, powerful regulatory institutions to improve the prudential regulation and supervision of wholesale and institutional financial markets even though many of the participants that operate in these financial markets are supposed to be sophisticated investors and powerful financial institutions. However, we are very surprised and concerned that the Commission has not followed through this logic and recognised the need to create a similar structure to ensure more consistent, coherent and robust retail regulation/ consumer and investor protection measures. We argue that there is equal, if not greater, need for improved consumer and investor protection regulation given the comparative lack of sophistication and power ordinary consumers and investors wield in financial markets. Therefore, we advocate the creation of a European Financial Users Authority with the objective of protecting users of financial services. It is difficult to identify any serious objections to establishing a similar institution to protect ordinary users. s initial view is that the remit and key activities of EFUA could be: coordinating the regulation and supervision of retail/ conduct of business activities this covers how firms treat consumers, efficiency of distribution, marketing and promotion, quality of advice and information provided to consumers, the behaviour of firms and intermediaries/advisers; investor protection issues; coordination of redress including financial institutions having efficient and fair procedures for handling complaints as well as consumers right to obtain redress if things go wrong; coordination of corporate governance and social responsibility of market participants; financial capability and information provision; coordinating the identification and prevention of consumer detriment at EU level; issuing risk warnings and guidance to national supervisors; coordinating relationships between relevant national supervisors, and consumer organisations. Response to the Commission s Communication on European Financial Supervision 12

14 Relationship with national supervisors We stress that we are not proposing the EFUA should supervise and monitor individual firms or EU markets. That role would remain with national supervisors. The EFUA would coordinate regulation at EU level and ensure consistent and coherent monitoring and enforcement of regulation. In this case, we are following the basic model envisaged for the European System of Financial Supervisors. As we outline above, we strongly support the creation of the ESFS as a mechanism for improving micro-prudential regulation in the EU and preventing regulatory arbitrage. We firmly believe that a similar structure for retail/ conduct of business regulation would deliver the same benefits for EU consumers and ensure a consistently high level of consumer protection across the EU. We feel that this must help in delivering our shared goal of a fair, effective, efficient, and inclusive EU single market in financial services that meets the needs of all the EU s citizens. We recognise the establishment of a EFUA would take some planning so as a first step we recommend that the Commission, supported by the existing level 3 committees, FIN-NET and, undertake detailed studies and planning in preparation for the creation of the new authority. We would be very happy to work with the Commission in developing a detailed list of issues to be covered in such a study. CONSUMER AND INVESTOR PROTECTION LEGISLATION We are pleased that the Commission is undertaking a series of initiatives intended to improve consumer/ investor protection alongside this Communication. These include initiatives relating to issues such as: packaged retail investment products; responsible lending; and promoting financial inclusion. However, we are concerned that these consumer protection initiatives appear not to be given the same priority as the macro- and micro- prudential regulatory reforms. There is a real contrast with the way the Commission is approaching macro- and micro- prudential regulatory reform and consumer/ investor protection reforms. We welcome the Commission's intention to bring forward, as soon as possible, the legislative changes to put in place the new framework for EU supervision, on the basis of the orientations set out in this Communication and after further consultation of stakeholders, so that the necessary measures are adopted in time for the renewed framework to be up and running during 2010; The Commission has demonstrated an impressive capacity for accelerating extremely complex macro- and micro- regulatory reforms and plans. It is self- Response to the Commission s Communication on European Financial Supervision 13

15 evident that the Commission has the capacity to apply the same resources and sense of urgency to consumer/ investor protection reforms and we urge it do so to protect users in the EU. Response to the Commission s Communication on European Financial Supervision 14