Structural reforms of EU Credit Institutions and transparency of securities financing transactions: Initial Appraisal of a European Commission Impact Assessment

17-11-2014

This note seeks to provide an initial analysis of the strengths and weaknesses of the Commission's Impact Assessment (IA) accompanying the two proposals on structural reforms of EU Credit Institutions and transparency of securities financing transactions. This initial appraisal refers primarily to the main analysis carried out in the IA, relating to credit institutions, supported by reference to the extensive body of annexes accompanying it. This appraisal is an initial analysis performed on a particularly complex and substantial body of work. Additional work can of course be performed on specific points, should the competent EP Committees so require. The main conclusions are that the IA on structural measures improving the resilience of EU Credit Institutions is a useful tool for policy-makers, which by and large respects the Commission's own internal IA guidelines. The parallel IA on reporting and transparency of securities financing transactions is usefully presented together with the first IA, signalling a positive shift of the Commission toward looking at IA in a more coherent manner. However, the level of analysis of this latter IA, seemingly introduced at a later stage of the process, appears to be less in-depth than the one on structural reforms. This note, prepared by the Ex-Ante Impact Assessment Unit for the Committee on Economic and Monetary Affairs (ECON) of the European Parliament, analyses whether the principal criteria laid down in the Commission’s own Impact Assessment Guidelines, as well as additional factors identified by the Parliament in its Impact Assessment Handbook, appear to be met by the IA. It does not attempt to deal with the substance of the proposal. It is drafted for informational and background purposes to assist the relevant parliamentary committee(s) and Members more widely in their work.

This note seeks to provide an initial analysis of the strengths and weaknesses of the Commission's Impact Assessment (IA) accompanying the two proposals on structural reforms of EU Credit Institutions and transparency of securities financing transactions. This initial appraisal refers primarily to the main analysis carried out in the IA, relating to credit institutions, supported by reference to the extensive body of annexes accompanying it. This appraisal is an initial analysis performed on a particularly complex and substantial body of work. Additional work can of course be performed on specific points, should the competent EP Committees so require. The main conclusions are that the IA on structural measures improving the resilience of EU Credit Institutions is a useful tool for policy-makers, which by and large respects the Commission's own internal IA guidelines. The parallel IA on reporting and transparency of securities financing transactions is usefully presented together with the first IA, signalling a positive shift of the Commission toward looking at IA in a more coherent manner. However, the level of analysis of this latter IA, seemingly introduced at a later stage of the process, appears to be less in-depth than the one on structural reforms. This note, prepared by the Ex-Ante Impact Assessment Unit for the Committee on Economic and Monetary Affairs (ECON) of the European Parliament, analyses whether the principal criteria laid down in the Commission’s own Impact Assessment Guidelines, as well as additional factors identified by the Parliament in its Impact Assessment Handbook, appear to be met by the IA. It does not attempt to deal with the substance of the proposal. It is drafted for informational and background purposes to assist the relevant parliamentary committee(s) and Members more widely in their work.