FESE agrees with the view that we do not need any fundamental structural changes to the current legislative framework in the context of European financial supervision. The work undertaken by the Committees of Supervisors is key to ensuring a coherent interpretation of the legislative provisions across Member States and an ongoing practice of exchange of information and supervisory cooperation among national Competent Authorities. FESE member exchanges believe that the priority should be to strengthen Level 3. Measures aimed at this objective could include the possibility for EU institutions to assess the performance of the Committees of Supervisors regularly and to intensify the cooperation among national supervisors (e.g. by encouraging the development of multilateral Memoranda of Understanding between supervisors or supporting colleges of supervisors). In the field of securities, we think that CESR, endowed with a different decision-making procedure and with an increased budget, should be the head of a network of supervisors; this would contribute to developing a unified approach to financial supervision and to obtaining full European integration.
In the response to DG Internal Market’s Public Consultation Paper on Amendments to the Commission Decisions establishing CESR, CEBS & CEIOPS, FESE gets to the core of the matter and comments on the mediation mechanism (stating that more transparency is needed concerning mediation cases and the processes followed and the outcomes of a mediation case should be disclosed to the public); the delegation of tasks between national supervisors; the colleges of supervisors; qualified majority voting in the context of the Colleges of Supervisors’ decision-making (supporting the proposal to include in the Decisions a request for the Committees of Supervisors to take decisions by qualified majority voting) and the Annual Work-Programmes of the Committees of Supervisors which, according to FESE, should be submitted to the European Institutions (Council, Commission and Parliament) after a comment period for the industry.
FESE Response_DG MARKT Consultation on Level 3 Decisions_July08.pdf
