Procedure : 2019/0818(NLE)
Document stages in plenary
Document selected : A9-0046/2019

Texts tabled :


Debates :

Votes :

Texts adopted :


PDF 321kWORD 103k


<Titre>on the Council recommendation on the appointment of a Member of the Executive Board of the European Central Bank</Titre>

<DocRef>(C9‑0173/2019 – 2019/0818(NLE))</DocRef>

<Commission>{ECON}Committee on Economic and Monetary Affairs</Commission>

Rapporteur: <Depute>Irene Tinagli</Depute>



on the Council recommendation on the appointment of a Member of the Executive Board of the European Central Bank

(C9‑0173/2019 – 2019/0818 (NLE))


The European Parliament,

 having regard to the Council’s recommendation of 8 November 2019 (13651/2019)[1],

 having regard to Article 283(2), second subparagraph, of the Treaty on the Functioning of the European Union, pursuant to which the European Council consulted Parliament (C9‑0173/2019),

 having regard to its resolution of 14 March 2019 on gender balance in EU economic and monetary affairs’ nominations[2],

 having regard to Rule 130 of its Rules of Procedure,

 having regard to the report of the Committee on Economic and Monetary Affairs (A9-0046/2019),

A. whereas, by letter of 14 November 2019, the European Council consulted Parliament on the appointment of Isabel Schnabel as Member of the Executive Board of the European Central Bank for a term of office of eight years, with effect from 1 January 2020;

B. whereas Parliament’s Committee on Economic and Monetary Affairs then proceeded to evaluate the credentials of the candidate, in particular in view of the requirements laid down in Article 283(2) of the Treaty on the Functioning of the European Union and in the light of the need for full independence of the ECB pursuant to Article 130 of that Treaty; whereas in carrying out that evaluation, the committee received a curriculum vitae from the candidate as well as her replies to the written questionnaire that had been sent to her;

C. whereas the committee subsequently held a hearing with the candidate on 3 December 2019, at which she made an opening statement and then answered questions put by the members of the committee;

D. whereas the Governing Council of the European Central Bank comprises the members of the Executive Board of the European Central Bank and the nineteen governors of the national central banks of the Member States whose currency is the euro; whereas, to date, all of the latter are men;

E. whereas Parliament has repeatedly expressed its disaffection regarding the appointment procedure for members of the Executive Board of the European Central Bank and has called for improved procedures in this regard; whereas Parliament has requested that it receive, in good time, a gender-balanced short list of at least two names;

F. whereas on 17 September 2019, Parliament delivered a favourable opinion on the Council recommendation to appoint Christine Lagarde as the first female President of the European Central Bank;

G.  whereas women continue to be underrepresented in the Governing Council of the European Central Bank; whereas Parliament deplores the fact that the Member States have not taken this request seriously and calls for the national and EU institutions to work actively towards achieving gender balance in the next nominations;

H. whereas all EU and national institutions and bodies should implement concrete measures to ensure gender balance;

1. Delivers a favourable opinion on the Council recommendation to appoint Isabel Schnabel as Member of the Executive Board of the European Central Bank;

2. Instructs its President to forward this decision to the European Council, the Council and the governments of the Member States.




November 2019

Full version:


Professor of Financial Economics

Institute for Finance & Statistics

University of Bonn

53012 Bonn

Telephone: +49-(0) 228 / 73 9202


Twitter: @Isabel_Schnabel

Personal data

Date of Birth August 9, 1971

Place of Birth Dortmund, Germany

Birth name Gödde

Citizenship German

Children Three children (2004, 2006, 2008)


Current position Professor (W3) of Financial Economics, Department of Economics, University of Bonn, since December 2015

Member of the German Council of Economic Experts (Sachverständigenrat zur Begutachtung der gesamt­wirtschaftlichen Entwicklung), since June 2014

Spokesperson of the Cluster of Excellence 2126 “ECONtribute – Markets & Public Policy” (Universities of Bonn and Cologne), since January 2019

Co-Chair of the Franco-German Council of Economic Experts, since October 2019

Research Affiliate at Max Planck Institute for Research on Collective Goods, Bonn, since September 2007

 Research Fellow at Centre for Economic Policy Research (CEPR), program area “Financial Economics,” since January 2015 (Affiliate since December 2006)

Research Affiliate and Member of the Executive Board of the Reinhard Selten Institute, Bonn and Cologne, since April 2017

Research interests Banking (banking stability and regulation, “too big to fail,” systemic risk)

International finance (financial crises, financial integration, capital flows)

Economic history (financial crises and institutions)

Financial law and economics

Academic career and education

March 2009 – November 2015 Professor (W3) of Financial Economics, Faculty of Law, Management and Economics, Johannes Gutenberg University Mainz

April 2007 – February 2009  Professor (W2) of Financial Economics, Faculty of Law, Management and Economics, Johannes Gutenberg University Mainz

May 2004 – August 2007  Senior Research Fellow (Postdoc) at Max Planck Institute for Research on Collective Goods, Bonn

September 2004 – March 2005 Visiting Postdoctoral Fellow, Department of Economics at Harvard University, Cambridge, USA

February 2003 – April 2004 Assistant Professor of Economics, Department of Economics, University of Mannheim

February 2003 Dissertation (Dr. rer. pol.), Department of Economics, University of Mannheim (summa cum laude), Dissertation Title: “Macroeconomic Risks and Financial Crises - A Historical Perspective,“ First Advisor: Martin Hellwig

1998 - 2003 Doctoral studies in the DFG graduate program “Allocation on financial markets” at the Department of Economics, University of Mannheim

 Research and teaching assistant at the Chair of Economics, Economic Theory (Martin Hellwig), University of Mannheim

November 1998  Diploma in Economics (“Diplom-Volkswirtin”), University of Mannheim (best of class) 

1997 – 1998 Ph.D. studies, Department of Economics,  
University of California, Berkeley, USA (one year)

1995 – 1997 Studies in Economics, Department of Economics,  
University of Mannheim

1995 Studies of the Russian language, Sankt Petersburg, Russia (one semester)

1994 – 1995 Studies in Economics, Sorbonne (Paris I), University of Paris, France (one semester)

1992 – 1994 Studies in Economics, Department of Economics,  
University of Mannheim

1990 – 1992  Professional training (“Banklehre”) at Deutsche Bank, Dortmund

1990 Graduation from secondary school (“Abitur”)

Other professional activities (only current activities)

Since September 2019 Member of Scientific Advisory Board of IZA – Institute of Labor Economics and Deutsche Post Stiftung

Since June 2019 Vice Chair of the Advisory Scientific Committee (ASC) of the European Systemic Risk Board (ESRB) (Member since March 2015)

Since January 2017 Deputy Chair of Scientific Advisory Board of Research Data and Service Centre (RDSC) at Deutsche Bundesbank (Member since June 2016)

Since April 2016 Chair of Advisory Board (Fachbeirat) of BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht) (Member since January 2008)

Since March 2014 Fellow of CESifo Network

Since May 2013 Member of Administrative Council (Verwaltungsrat) of BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht)

Since July 2012 Member of Scientific Advisory Council of the Centre for European Economic Research (ZEW), Mannheim (currently inactive)

Selected awards 

Since 2019 Member of North Rhine-Westphalian Academy of Sciences, Humanities and the Arts

Since 2018 Member of Berlin-Brandenburg Academy of Sciences and Humanities

2018 Stolper Prize, Verein für Socialpolitik

2018 Prize of the Monetary Workshop “for contributions to financial market theory and banking regulation as well as analyses of systemic financial crises”

2010 Best Teaching Award, Department of Economics, Goethe University Frankfurt

2000 Best Teaching Award, Department of Economics, University of Mannheim

1993 – 1998 Scholarship of German National Academic Foundation (“Studienstiftung des Deutschen Volkes”)


Language skills German (native speaker), English (fluent), French (very good), Russian (basic)


Publications in refereed journals (selection)

“Asset Price Bubbles and Systemic Risk,” with Markus K. Brunnermeier and Simon Rother, Review of Financial Studies, forthcoming.

“Foreign banks, financial crises and economic growth in Europe,” with Christian Seckinger, Journal of International Money and Finance, 2019, 95, 70-94.

“A new IV approach for estimating the efficacy of macroprudential measures,” with Niklas Gadatsch and Lukas Mann, Economics Letters, 2018, 168, 107-109.

“Financial Sector Reform After the Crisis: Has Anything Happened?”, with Alexander Schäfer and Beatrice Weder di Mauro, Review of Finance, 2016, 20(1), 77-125.

“Financial Integration and Growth – Why Is Emerging Europe Different?”, with Christian Friedrich and Jeromin Zettelmeyer, Journal of International Economics, 2013, 89, 522-538.

“Competition, Risk-Shifting, and Public Bail-out Policies,” with Reint Gropp and Hendrik Hakenes, Review of Financial Studies, 2011, 24(6), 2084-2120.

“Bank Size and Risk-Taking under Basel II,” with Hendrik Hakenes, Journal of Banking and Finance, 2011, 35, 1436-1449.

“The Threat of Capital Drain: A Rationale for Regional Public Banks?”, with Hendrik Hakenes, Journal of Institutional and Theoretical Economics, 2010, 166(4), 662-689.

“How Do Official Bailouts Affect the Risk of Investing in Emerging Markets?,” with Giovanni dell'Ariccia and Jeromin Zettelmeyer, Journal of Money, Credit, and Banking, 38(7), October 2006, 1689-1714.

“Liquidity and Contagion: The Crisis of 1763,” with Hyun Song Shin, Journal of the European Economic Association, 2(6), December 2004, 929-968.

“The German Twin Crisis of 1931,” Journal of Economic History, 64(3), September 2004, 822-871.

Policy-related publications (selection)

Target-Salden, Leistungsbilanzsalden, Geldschöpfung, Banken und Kapitalmärkte [Target Balances, Current Account Balances, Money Creation, Banks and Capital Markets], with Martin Hellwig, Wirtschaftsdienst, 99(9), 2019, 632–640.

Verursachen Target-Salden Risiken für die Steuerzahler? [Do Target Balances Create Risks for Taxpayers?], with Martin Hellwig, Wirtschaftsdienst, 99(8), 2019, 553–561.

Completing Europe’s Banking Union means breaking the bank-sovereign vicious circle, with Nicolas Véron, VoxEU column, 16 May 2018, available at

Breaking the stalemate on European deposit insurance, with Nicolas Véron, VoxEU column, 6 April 2018, available at

Reconciling risk sharing with market discipline: A constructive approach to euro area reform, with Agnès Bénassy-Quéré, Markus K. Brunnermeier, Henrik Enderlein, Emmanuel Farhi, Marcel Fratzscher, Clemens Fuest, Pierre-Olivier Gourinchas, Philippe Martin, Jean Pisani-Ferry, Hélène Rey, Nicolas Véron, Beatrice Weder di Mauro, Jeromin Zettelmeyer, CEPR Policy Insight No. 91.



A. Personal and professional background

1. Please highlight the main aspects of your professional skills in monetary, financial and business matters and the main aspects of your European and international experience.

I have been a Professor of Financial Economics since 2007, first at the University of Mainz and until now at the University of Bonn. My research has always been closely related to monetary and financial topics.

Among many other things, I have worked on the causes and responses to financial crises, with a particular focus on the issue of banks being too big to fail and implications for bank regulation. Moreover, I have analysed the occurrence and consequences of financial bubbles and have shown how fragilities in the financial sector contribute to the vulnerabilities arising from asset price bubbles. I also considered the role that central banks as well as macroprudential policies may play in dealing with financial bubbles. Other papers considered the amplification of financial disturbances through fire sales of assets and how central banks can deal with such undesirable market dynamics. Another field of my research considers the impact of financial integration on economic growth. One of my papers pointed towards the economic damage induced by the breakdown of financial integration in the euro area crisis. Finally, part of my research has focused on topics closely related to the Banking Union, such as the determinants of the sovereign-bank nexus and the impact of bank resolution regimes on systemic risk.

My work has been both theoretical and empirical with a stronger emphasis on the latter. Part of my work has focussed on historical episodes, going back as far as the 17th century, looking for example at the role that early banks and central banks played for monetary and financial stability. My research, which is co-authored by many national and international researchers, has been published in internationally renowned scientific journals and received important third-party academic funding, such as through the Cluster of Excellence ECONtribute – Markets & Public Policy, which is funded by the German Research Foundation in the context of the German Excellence Strategy.

Moreover, I have gained a lot of policy experience through my membership in the German Council of Economic Experts, the key independent economic advisory body to the German government, of which I have been a member since 2014. In that capacity, I have worked intensively on topics related to financial and monetary stability, in particular, the reform of the euro area architecture (Banking Union, Capital Markets Union and ESM reform). For example, we have developed proposals on how sovereign exposures could be regulated, which seems to be one of the key ingredients of a package leading towards the completion of Banking Union. Other topics concerned the challenges facing the German and European banking sectors, including those from structural change in the course of digitalization.

I have been a member of many other committees in the area of monetary and financial economics. Since 2015, I have been a member and since 2019 Vice Chair of the Advisory Scientific Committee (ASC) of the European Systemic Risk Board (ESRB). In that capacity, I was part of the Task Force on Low Interest Rates and was one of the authors of the recently published ASC report dealing with the (potentially excessive) complexity of financial regulation. Since January 2016, I have been a member and since 2017 Deputy Chair of the Scientific Advisory Board of the Research Data and Service Centre (RDSC) at Deutsche Bundesbank. Since 2008, I have been a member and since 2016 Chair of the Advisory Board (Fachbeirat) of the German financial supervisor BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht). Through these and other activities, I have been able to build a broad network in the central banking and supervisory sphere across Europe and beyond.

I have also contributed to numerous policy-related publications. I would like to emphasize my participation in the French-German “7 plus 7 Report”, which proposes a broad set of euro area reforms and has been well-received by both academics and policymakers. This report underlines my engagement for Europe, which also shows up in many other of my policy-related publications. For example, I developed a model for European deposit insurance (jointly with Nicolas Véron). In light of my previous work related to European issues, I was recently nominated as a member and elected as Co-Chair of the French-German Council of Economic Experts, founded on the basis of the Aachen Treaty by the French and the German governments.

I have received a number of awards for my scientific and policy work, including among others the membership in the North Rhine-Westphalian Academy of Sciences, Humanities and the Arts as well as in the Berlin-Brandenburg Academy of Sciences and Humanities, the Stolper Prize of the Verein für Socialpolitik (the association of German-speaking economists) for my contributions to economic policy through my research, and the prize of the Monetary Workshop, which is an annual prize for outstanding scientific or practical achievements in the monetary field.

I have always been vocal in the public debate, which is reflected in numerous interviews and newspaper articles, as well as in an active Twitter account. Recently, I was ranked as the most influential female economist in the German-speaking area by the German newspaper FAZ. Most importantly, I have always been open to good arguments, while defending the views that I considered appropriate.

2. Do you have any business or financial holdings or any other commitments which might conflict with your prospective duties, and are there any other relevant personal or other factors that need to be taken account of by the Parliament when considering your nomination?


3. What would be the guiding objectives you will pursue during your mandate at the European Central Bank?

My main objective would be to fulfil the ECB’s mandate of price stability, while preserving the central bank’s independence. A second objective would be to contribute to fostering a culture of thorough, data-driven analysis to reflect on and improve monetary policy and address new developments, such as digital change or climate change. Such an approach would be useful in the upcoming review of the monetary policy framework. Finally, I would strive to better communicate the ECB’s policies to the public in order to raise people’s understanding of the ECB’s decisions and underlying reasoning, while remaining open to criticism.

B. ECB monetary policy

4. In your view, how should the ECB conduct its monetary policy in the current macroeconomic conditions? How do you see the ECB’s performance regarding the achievement of its primary objective of maintaining price stability? The German Council of Economic Experts has been arguing for a “monetary policy turnaround” since 2017. What is your opinion? Could you spell out this turnaround?  

Over the past 20 years, the ECB has been very successful in achieving its primary objective of price stability. In fact, average HICP inflation has been 1.7 percent over this time period, which is broadly in line with an inflation rate of below, but close to, 2 percent. This is remarkable because this was a difficult time period including the largest financial crises experienced since the Great Depression. The main threat in that time period was not excessive inflation, as some had feared initially, but rather deflationary pressures after the financial crises. The ECB’s determined policy was able to avert these deflationary risks. When interest rates reached the “zero lower bound”, the ECB had to revert to an “unconventional monetary policy”, which overall proved highly successful. In all these years, the ECB’s policy was guided by its mandate and always remained firmly within its mandate’s boundaries. Research has shown that ECB policy has contributed not only to higher inflation but also to higher economic growth and lower unemployment.

The current situation is characterized by a global downturn, related to rising uncertainty in response to the trade conflict and the looming Brexit. The slowdown is reflected in a weakness of industry and a decline in investment demand. As a consequence, growth in the euro area has slowed as well. So far, in many countries, growth in the services sector is still stable, and consumption growth and the labour market are robust. There is, however, a danger that the weakness in the manufacturing sector may spill over to other parts of the economy, depressing consumers’ and firms’ confidence and therefore consumption and investment.

Since the ECB is committed to maintaining price stability in the euro area, it has to watch these developments very carefully. Inflationary pressures have been muted and current economic development may add further downside pressures. Current projections over the next couple of years show that inflation is still not in line with the ECB’s objective. Therefore, an accommodative monetary policy continues to be needed. At the same time, side effects have to be watched carefully to make sure the balance between positive effects and side effects remains in positive territory.

The German Council of Economic Experts’ economic outlook in 2017 and 2018 was very different from the situation we are facing today. At the time, the German Council of Economic Experts projected a considerable pick-up in consumer prices in the near term. The projection for euro area inflation in 2017 was raised by 0.6 percentage points between November 2016 and March 2017, from 1.3% to 1.9%.

Due to the significant slowdown in euro area growth dynamics, this acceleration in price dynamics has not materialised. This has also been acknowledged by the German Council of Economic Experts in their latest report published in November 2019. A turnaround of monetary policy would therefore not be appropriate at this stage. The monetary policy rules (such as the conventional Taylor rule) presented by the German Council of Economic Experts should be read as positive, rather than normative concepts. In particular, the estimation of these rules relies on a stable underlying structure. If there is a structural break in the underlying series, the rules cannot be used to judge whether the current policy stance is appropriate.

The German Council has stressed potential side effects of monetary policy, which have also been discussed in the Governing Council because they may affect monetary transmission. One example are the potential side effects on financial stability. An extended period of low interest rates affects property prices, and the ESRB has issued warnings and recommendations towards a number of Members States due to potential exaggerations in the residential property market. Such vulnerabilities are primarily to be addressed by macroprudential policies, which can also be adjusted to the specific situations in individual countries. Moreover, stretched valuations especially in metropolitan areas also reflect migration into large cities and an undersupply of housing. Hence, a much broader policy response including macroprudential and housing policy is required.

5. What do you think about the 12 September ECB Governing Council stimulus package, and decision on forward guidance? How do you view the way this decision has been made, in particular in light of the public opposition of some members of the ECB Council following the decision? More generally, how do you view the way monetary policy decisions have been made in the past and do you think it should be changed and, if so, how?

The decisions by the ECB’s Governing Council in September reflected the slowdown in economic growth observed over the past months. Given lower inflationary pressure, these decisions can be justified by current inflation data as well as the outlook for inflation over the medium term, which is not yet converging to the objective of below, but close to, 2 percent.

The decisions also reflect the difficulty in keeping up the monetary stimulus when interest rates are close to the effective lower bound. The decided set of measures should be able to give further support to the real sector by maintaining favourable funding conditions. Forward guidance was adjusted in a clever way by linking future measures directly to the inflation outlook, which provides more transparency about the ECB’s reaction function and makes it easier for market players to anticipate how the ECB is going to respond to changes in the underlying data. The decisions on interest rates are discussed in the next question.

From the media reporting, I take it that the Governing Council agreed unanimously that an accommodative monetary policy stance is needed in the current situation. I fully subscribe to this view. Views differed, however, regarding specific monetary policy instruments, especially regarding the need to restart the asset purchases. Such disagreements reflect the inherently difficult situation rather than problems in the decision-making progress. In fact, I view the decision process of the Governing Council very positively. I understand the decisions were taken according to the rules after everybody, including non-voting Council members, had the chance to be heard.

6. How do you evaluate the effects of low interest rates? The German Council of Economic Experts has frequently warned against inflationary pressures because of the ECBs monetary policy stance and recommended interest rate increases. How do you explain that the inflationary pressures did not materialize and which consequences do you draw from these counterfactual predictions?

Overall, the experience with low and even negative interest rates in the euro area appears to have been positive. The transmission of policy rates to financing conditions seems to have worked smoothly, with benefits to the economy.

Low interest rates have, however, raised concerns in the population who are afraid that these low rates endanger their ability to save, especially for old age. In fact, low interest rates are reflecting long-term underlying trends, such as ageing societies and the shift towards less capital-intensive sectors, and cannot be attributed to monetary policy alone. In any case, an increase in ECB policy rates would hardly contribute to improving the people’s situation.

The Governing Council is watching negative side effects carefully and has shown to be willing to counteract them. The ECB’s decision to introduce a tiering system for reserve remuneration can be seen in this context, as it reduces the burden on banks from holding negatively remunerated excess reserves at the central bank.

The experience in recent years has shown that the effective zero lower bound is lower than a nominal rate of zero. There may, however, be an interest rate, below which monetary policy may become less effective. This reflects the potentially negative side effects of low and negative interest rates on banks’ profitability, which may limit the transmission of monetary policy to the real economy. Of course, these effects also hinge on the question whether negative interest rates can be passed on to firms and households, which appears to be difficult, especially for retail customers. In general, profitability is likely to be affected more by the slope of the yield curve than by the level of interest rates. Moreover, bank profitability is likely to benefit from a lower number of loan defaults due to a more benign economic environment, as shown by recent research. While bank profitability is not a goal of monetary policy, an unprofitable banking sector may become an obstacle to monetary transmission.

The outlook in 2017 and 2018 – when the German Council of Economic Experts argued for terminating asset purchases earlier and communicating a normalization strategy – was very different from today. At the time, output growth was at or possibly even above potential. Over time, this could have stimulated more robust consumer price dynamics which, had they proven sustainable and long-lasting, also would have justified a tightening of the monetary policy stance at some point. Note, however, that the German Council did not speak in favour of interest rate increases at that time. It merely feared that – in the future – such increases may occur too late. The German Council’s forecasts of inflation generally were in the same range as other forecasts, including that of the ECB.

In light of my nomination, I abstained from signing those parts of the most recent report referring to monetary policy. Note that the report this time did not argue for normalization. However, the German Council was not in favour of restarting asset purchases.

7. Twenty years after the introduction of the euro, do you think the time has come for conducting a review of the ECB monetary policy framework?

Over the period since the inception of the euro, the ECB’s monetary policy framework has proven to be very successful. The ECB was able to maintain the objective of price stability even at times of deep crises, market fragmentation and bank failures. But in the past twenty years, the macroeconomy and monetary policy have evolved quite substantially. The monetary toolkit has expanded to deal with the challenges of monetary policy close to the zero lower bound. While the existing framework has been successful in maintaining price stability in the euro area, the calibration of instruments has become more challenging.

The previous review of the ECB’s monetary policy framework took place in 2003. Hence, it seems appropriate to carry out a comprehensive review, with the objective of making sure that the ECB’s monetary operations can achieve the goal of price stability in the best possible way. Hence, I fully support Christine Lagarde’s intention to launch a strategic review in the near future and I will be happy to contribute to it. Importantly, such a review has to be based on a careful evaluation of previous monetary policy measures in light of their ability to contribute to fulfilling the mandate. This should also include an analysis of potential side effects that may affect monetary transmission.

As an Executive Board member, I would be happy to openly discuss these matters within the Governing Council, and jointly with the ECB staff. What is important is that any changes to the monetary policy framework indeed lead to an improvement. In some cases, clarifications may be desirable. Generally, one should be aware that central bank credibility may be affected negatively when the operational objective is adjusted at a time when it is difficult to be reached. Therefore, any adjustments should be conducted with great care and on the basis of a strong empirical underpinning.

8. How will you ensure transparency regarding the implementation of the Asset Purchase Programme (APP)? Do you agree that more transparency could be provided on the Asset-Backed Securities Purchase Programme (ABSPP) and the third Covered Bond Purchase Programme (CBPP3)?

Transparency is of vital importance for any central bank operation and ensures accountability, as has always been acknowledged by the ECB. At the same time, ensuring the appropriate degree of transparency is a balancing act for the ECB.

On the one hand, limits to transparency are justified if there is the risk that transparency may limit the effectiveness of monetary policy. Specifically, it has to be avoided that financial actors get ahead of the central bank, which could be the case if details were published on the holdings of individual securities.

On the other hand, the ECB should provide the information needed to evaluate its actions. For this reason, the ECB displays a high degree of transparency regarding monetary policy implementation, including the Asset Purchase Programme (APP). In particular, the ECB publishes the monthly volumes of purchases, total holdings, as well as redemptions, each by programme, on its website.

Overall, in my perspective, the current degree of transparency reflects the trade-off between accountability and concerns about limiting monetary policy effectiveness in a reasonable way.

9. What are your views on the risks associated with the Corporate Sector Purchase Programme (CSPP)? How do you evaluate the currently increasing share of the CSPP on the primary market and at the same time the currently decreasing share of the public sector purchase programme on the secondary market?

Since 2016, the ECB has been buying bonds of the private, non-financial sector under the Corporate Sector Purchase Programme (CSPP). Overall, the CSPP aims to improve financing conditions for corporations in the euro area more directly, thereby exerting an impact on investment and hence the real economy.

The purchases are conducted on both the primary and the secondary market, based on certain eligibility criteria, including limits to the share of issuances and issuers. This ensures that only assets with sufficient credit quality are bought.

According to market conditions, the share of purchases on the primary and secondary market and across ECB instruments may vary. Such fluctuations reflect the flexibility needed for the smooth implementation of the APP, in particular by taking into account considerations about market liquidity and issuance patterns. The adjustment of the portfolio across policy instruments and jurisdictions to the programme parameters has to be gradual in order to safeguard orderly market conditions. These fluctuations do not signal a change in the calibration of the APP: The ECB has communicated that it can continue its net purchases for an extended period of time within the current programme parameters.

However, on the CSPP side, there is the danger of prioritizing certain firms over others, in particular larger over smaller companies. Therefore, the ECB makes sure to buy a broad range of corporate bonds, including smaller issues. However, smaller companies tend not to issue bonds at all. But there is evidence showing that the positive effects on funding costs have spillover effects on small and medium-sized companies.

In general, the scope of the CSPP hinges on the role of market financing for firms in the euro area. Given the relatively small role of bonds for firm financing, the scope of the CSPP is also limited.

10. How in your view can the ECB contribute to economic growth, ecological transition and full employment while fully complying with its primary objective to maintain price stability? Are there in your view possible additional monetary policy measures that would improve the positive effects on the real economy?

While the ECB policy has to be guided first and foremost by its primary objective to maintain price stability, as enshrined in Article 127(1) of the Treaty on the Functioning of the European Union (TFEU), the same article adds that, “[w]ithout prejudice to the objective of price stability, the ESCB shall support the general economic policies in the Union with a view to contributing to the achievement of the objectives of the Union as laid down in Article 3 of the Treaty on European Union”.

In general, a monetary policy fostering price stability is likely to also support economic growth and employment. The creation of millions of jobs in the euro area in recent years would not have been possible without the ECB’s policies. The ECB’s highly accommodative monetary policy has strengthened consumer spending and private investment in the euro area, thereby promoting economic growth and reducing unemployment. The ECB’s monetary policy measures in September have further contributed to ensuring very favourable financing conditions. Hence, the ECB’s measures continue to benefit the real economy.

The ECB is currently developing its views on how it can support climate policies. For this purpose, it participates in the Network for Greening the Financial System (NGFS), a collaboration of a large group of central banks, supervisors and international institutions. Within this group, it engages in developing views on relevant aspects of climate change and how the central bank and supervisory policies can both adapt to and help to mitigate climate change. Since this work appears to be still in an infant stage, I look forward to engaging in this debate.

While reflections within central banks seem at this stage more geared towards the monitoring and management of risks stemming from climate change, the monetary policy side of the ECB is facing the question of how to integrate climate-change related developments into its analysis and whether and how it can contribute to climate change mitigation, including through its asset purchase programme.

One aspect that needs to be addressed is the risk assessment of assets with respect to climate-related risks (CRRs) as well as the consequences for financial stability. There is a need to incorporate climate risk into risk models. More work is needed to understand how this can be done. Based on such models, the ECB should consider such risk factors also in its micro- and macroprudential supervisory tasks as well as in its assessment of haircuts in asset purchase programs. A more difficult question is whether the ECB should prefer “green” over “brown” bonds in its asset purchasing programmes (see the next answer on this point).

11. What is your view on the steps needed to finance the European Green Deal?  What are your views on the impact of the ECB policy on climate change? Do you think the ECB should bring its asset purchases in line with the UN’s sustainable development goals and the Paris climate agreement? Should the ECB’s asset purchase programmes be in line with EU taxonomy framework? What role would the ECB play in the Network for Greening the Financial System?

The new European Commission has rightly made the European Green Deal one of its main priorities. Given the global nature of the problem, cooperation is needed not only on a European but on a global level. In any case, in view of the urgency of the matter, all economic policy actors, including central banks, need to incorporate the fight against climate change in their agendas.

European policy makers can thus make a difference by tackling this challenge together. For instance, the EIB will play an important role in financing climate-related investments. According to the Commission’s plans, these actions will be reinforced by the EU budget, which, also in the context of the Sustainable Europe Investment Plan, can provide vital support to finance the transition. Additional efforts will be required to mobilise private funds, which could be achieved through co-funding structures. The EU Sustainable Finance Action Plan is another important element in contributing to the financing of the European Green Deal.

A proper classification of assets according to their sustainability is crucial for guiding investment decisions. The taxonomy of green investments is at the core of these activities and helps to guard against “greenwashing”. This taxonomy, once adopted and implemented, will lay the foundation for any sustainable investment policy and for further measures in this area.

Most economists agree that the introduction of carbon pricing is the most efficient way to pursue climate policies and to achieve the goals of the Paris agreement (see also the German Council of Economic Experts’ special report of this year on carbon pricing). By making carbon-intensive activities more expensive, carbon pricing sets the right incentives for individuals and firms as well as for innovation. In addition, the ecological transition requires private and public investment (e.g. in infrastructure and research & development) as well as a social cushioning of undesirable distributional effects. For this reason, there is also a broad consensus that revenues from carbon pricing should to a large part be returned in the form of redistributive spending. A comprehensive system of carbon pricing in principle provides proper incentives to redirect capital flows in the desired direction. Therefore, the introduction of carbon pricing across all sectors of the economy should be a priority of governments.

The ecological transition will affect the macroeconomic environment in which the ECB operates. Therefore, it has to reflect on its role in this changing environment, while clearly staying within the limits of its mandate. The decision to join the Network for Greening the Financial System, as mentioned above, is a first step in this regard and clearly shows the ECB’s commitment to contribute to the dialogue and to develop policies for central banks and supervisors. I understand and welcome that the ECB takes an active role in the Network. Christine Lagarde has shown great openness to the issue of climate change and will certainly open a debate on how the ECB can contribute to addressing climate change within its mandate. I will be more than happy to contribute to this debate.

So far, the ECB asset purchases are based on the principle of market neutrality. As Christine Lagarde wrote recently in a letter to Mr. Urtasun, Member of the European Parliament, “the operational concept of market neutrality has been considered the most appropriate concept to, on the one hand, ensure the effectiveness of the ECB’s monetary policy measures from a price stability perspective and, on the other hand, respect the principle of an open market economy.” As mentioned in that letter, the review of the monetary policy framework will also be used to reflect on the question how sustainability considerations can be integrated.

It should be noted that the current asset purchase programme is already providing favourable financing conditions for companies and governments to finance the ecological transition. In fact, the ECB is purchasing considerable amounts of public and private green bonds. With green bonds gaining importance in the market, this will improve the liquidity of some markets and automatically translate into greater importance of green bonds in the APP.

Giving preference to green bonds should be carefully assessed. It could lead to an overburdening of the central bank whose decisions are guided by its mandate of price stability.

12. Should the ECB in your personal view buy more EIB bonds to help financing European investments in line with the ECB primary and secondary objectives?

Bonds issued by the EIB and other supranational institutions are already part of the public sector purchase programme and will also be bought under the resumed asset purchases. According to the rules, the ECB purchases these bonds in the secondary market subject to maximum purchasing limits, which are now at 50%. Currently such bonds make up 12%of the overall purchases. With increased bond issues by the EIB, the share of EIB bonds in asset purchases could possibly be raised within the given rules.

13. What is your view on the implementation of the Emergency Liquidity Assistance (ELA)? What could be improved in the decision-making process on granting ELA?

Emergency Liquidity Assistance (ELA) plays a crucial role in crisis situations. It is exceptionally given to solvent banks who are facing short-term liquidity problems and who cannot rely on the main refinancing operations, e.g. due to a lack of eligible collateral.

It was decided that ELA activities are conducted at national level (see Article 14.4 of the ESCB Statute). This implies that the costs and risks from ELA are also borne at national level. In order to avoid that ELA interferes with the ECB’s objectives, there are a number of safeguards, depending on the size of the envisaged support, which may even lead to the prohibition of the execution of the operations if they are deemed to interfere with the single monetary policy of the Eurosystem. The agreement on ELA adopted in July 2017 defines the allocation of responsibilities and the framework for sharing information to prevent any such interference.

Overall, ELA has proven effective in dealing with short-term liquidity shortages at euro area financial institutions. In the future, given the relevance of cross-border spillovers especially with respect to liquidity stress, it could be discussed whether ELA should be provided at European level. Given that the European banking and capital market is going to become more and more integrated in the process of completing the Banking Union and of creating the Capital Markets Union, there are additional arguments for shifting the important role of the provision of emergency liquidity to supranational level. This could also facilitate coordination with other authorities, like the SRB, in crisis situations. Some have feared that this could slow down the provision of liquidity in the middle of a crisis. Such concerns would have to be taken into account.

14. Which role do you think the ECB should play in addressing virtual currencies? Which chances and risks do you see with regard to virtual assets? What would you consider an appropriate regulatory framework for virtual currencies (and “stable coins” in particular) to look like?  

In the past decades, a large number of virtual currencies have been developed based on blockchains and distributed ledger technology. So far, these virtual currencies have not been able to fulfil the functions of money, mainly due to the high volatility of their valuations. Therefore, most virtual currencies are not effectively used as a means of exchange and can rather be considered as speculative assets.

More recent private initiatives, most importantly the Libra initiative by Facebook and the Libra Association, have improved upon previous virtual currencies like Bitcoin in two respects: they are backed by assets, which stabilizes their value (therefore, they are called “stablecoins”); and they can rely on the huge networks of their providers, such as Facebook. Stablecoins can have the advantage of facilitating payments, especially in a global context, by reducing costs and increasing speed. Moreover, they may play a useful role in the developing world where many people do not have access to banks but can use their mobile devices to make payments.

However, stablecoins come along with important risks. Stablecoins are a new technology that is largely untested. In order to reap their potential, inherent risks must be addressed. Consumers are facing various risks, related to the currency’s value and liquidity as well as to privacy, because payment transactions may in principle be linked to other information in the given network. A second important risk refers to the danger of illegal payments, such as terrorist financing or money laundering, which may be hard to control in these settings. A third risk concerns financial stability. Depending on the exact implementation, there may be risks of runs, giving rise to fire sales and potentially spilling over to the rest of the financial system. Finally, again depending on the exact design, stablecoins may affect monetary transmission.

It is thus important to work on defining appropriate regulation. Important areas concern governance, financial integrity, safety (including protection from cyber risk), data and consumer protection, as well as financial stability. At the same time, innovation should not be stifled by regulation, which should follow the principles of “same business, same rules”, technological neutrality and proportionality.

Stablecoins arrangements may easily become systemic, given the potential size and global spread. This implies that their oversight would fall under the remit of the Eurosystem. The ECB also has the responsibility to promote the smooth functioning, safety and efficiency of the payment system. Given the global scale of stablecoin arrangements operating cross-border, any regulatory approach has to be based on global collaboration. Therefore, the ongoing initiatives at G7 level are crucial.

The appearance of virtual currencies in general and stablecoins in particular can be seen as an indication that the current payment system is subject to inefficiencies, which should be addressed. The ECB has been committed to improve payment systems in the past and should continue to do so in the future in its functions as payment system operator, overseer and catalyst for change.

15. How do you assess the interactions between payment systems and monetary policy? What should be the role of the ECB, as central bank of issue, on Central Counterparty Clearing houses (CCPs)?

Payment systems play an important role for monetary policy. If, for example, stablecoins were increasingly used as a store of value and lending was also taking place in stablecoins, domestic monetary transmission could be weakened substantially. The degree would, in this particular case, depend crucially on which currencies are included in the reserve basket. In any case, the ECB has a strong interest in monitoring the development of private payment systems to maintain its control over monetary policy.

Central counterparties (CCPs) are another important actor in the financial system. Over the past decade, the growth of central clearing has increased the systemic importance of CCPs across multiple jurisdictions. Therefore, the revised regulatory framework (EMIR 2) will be key to reduce risk, and help prevent future financial system collapses. EMIR 2 will, in particular, strengthen EU supervision of systemically relevant CCPs that are located outside the euro area and clear significant amounts of euro-denominated instruments. It will ensure involvement of central banks of issue (i.e. the ECB in the euro area), which will be able to perform oversight activities.

The SSM Regulation explicitly states that the ECB is not the supervisor of CCPs. Nevertheless, there are close connections between central clearing, the payment system and the ECB’s mandate.

First, the functioning of the euro repo market, which is crucial for monetary policy transmission, depends to a large extent on CCPs. Therefore, the ECB has a keen interest in avoiding or mitigating disruptions in the euro repo market related to or affecting CCPs. Second, CCPs play an important role in the payment system by channelling large amounts of liquidity, while serving as financial market hubs through which distress can spread quickly. Third, the ECB may be called upon to provide emergency liquidity support to banks participating in CCPs or to CCPs themselves.

16. Which role do you see for cash-based transactions compared to digital transactions in the future?

While the use of cash is likely to decline further, I believe that it is unlikely to disappear in the years to come.

Data clearly shows that cashless transactions have grown substantially over the past years. Digitalisation and innovation have been key drivers. At the same time, there is a large heterogeneity across Member States, and cash remains the favourite payment instrument for certain types of transactions. This resilience in the use of cash is due to its unique features, such as privacy. Moreover, its use does not require IT infrastructures. Cultural factors can also play a role.

Therefore, I believe that although payment habits can be expected to change rapidly, not least through the increasing use of digital wallets, cash is likely to remain popular in certain countries and among certain user groups.

17. What are your views on high denominations notes in euros?

In day-to-day life of ordinary citizens, high-denomination bank notes play a minor role. However, they may matter as a store of value and as means of payment to purchase expensive items. At the same time, they may facilitate illicit activities, thanks to the possibility of transferring large amounts at low transportation costs.

Therefore, all Eurosystem central banks stopped the issuance of 500 euro banknotes at the beginning of the year. It is important to clarify that the 500 euro banknotes retain their value and remain legal tender. The circulation of such banknotes will gradually decrease and, eventually, these banknotes will be withdrawn from circulation.

Overall, the consequences of this withdrawal will be minor for citizens. Legitimate activities will be conducted on the basis of banknotes with smaller denominations, while illegal activities may find their way in the digital sphere. Therefore, the control of digital payment systems may play a larger role in the fight against illegal payment transactions in the future than the abandonment of large banknotes.

18. What is your view on the heterogeneity of monetary conditions and access to credit across the euro area and its impact on unitary monetary policy of the ECB?  

Before the global financial crisis, it seemed that monetary conditions and access to credit had largely converged, facilitating the transmission of monetary policy. However, the crisis caused lending conditions to diverge dramatically across Member States, which impaired the transmission of monetary policy to businesses and households.

In recent years we have seen a substantial improvement of monetary conditions and access to credit in the euro area, which is to a large extent due to the ECB’s accommodating measures. The easing measures that started in the middle of 2014 were able to reduce bank lending rates in the euro area to a significant extent. In addition, their cross-country variation declined as well, implying a substantial easing of financial conditions for firms and households all over the euro area. These favourable funding conditions have contributed to bank loan growth, which in turn positively affected private investment and consumption and thereby contributed to stronger economic growth.

Overall, thanks to the ECB’s measures the single monetary policy in the euro area, which was inhibited during the crisis, has now been restored. The more homogeneous monetary conditions helped the ECB to safeguard its monetary policy transmission mechanism.

19. Several EU Member States are preparing to join the euro area. How do you foresee avoiding further divergences between euro area Member States over the coming decade in light of the economic conditions in candidate states? What is the preferred economic scenario of euro area enlargement?  

Adoption of the euro requires an appropriate degree of convergence. Therefore, the ECB and the European Commission publish regular reports discussing the progress made by non-euro area countries with respect to convergence. This includes each country’s progress toward achieving the Maastricht criteria. Beyond this, the reports also consider whether the convergence process is sustainable, which also hinges on institutional factors.

Moreover, given the establishment of the Banking Union, euro adoption implies participation in common banking supervision, i.e. in the SSM. Therefore, countries that wish to join the euro are expected to enter into close cooperation with ECB banking supervision prior to adopting the euro, and to meet specific reform requirements. The process for establishing the close cooperation is established in the SSM Regulation and the ECB Decision on the matter. Once the close cooperation is established, significant banks in the country will be supervised by the ECB via instructions given to the national competent authority. This thorough and careful preparation is to ensure a smooth transition towards the exchange-rate mechanism and ultimately the euro.

According to the Treaties, with the exception of the UK and Denmark who are subject to an opt-out clause, all EU Member States are eventually expected to adopt the euro.

20. What are the main risks/opportunities ahead for the euro?  

The first twenty years of the euro have posed severe challenges for the common currency. But the European Economic and Monetary Union (EMU) has weathered these challenges very well. After 20 years, the citizens’ support for the euro stands at a record high, with 76% expressing their support for the single currency. Even in the middle of the crisis, the support for the single currency among the population and among most European Leaders remained high.

The euro has brought numerous advantages to the Member States and their citizens: a large domestic market underpinned by monetary stability, lower funding costs, as well as lower transaction costs and the absence of exchange rate risk in cross-border trade and investment. Of course, the crisis has exposed severe weaknesses of the euro area architecture in the financial, fiscal and economic sphere. Financial fragmentation, insufficient countercyclical fiscal policies and a low pace of structural reforms posed a significant challenge for the euro area. But substantial progress has been made, not least through the establishment of the Banking Union, including common supervision and a single resolution mechanism, as well as the ESM.

However, further steps are needed to stabilize the euro area in a sustainable way and fully reap the benefits from the Single Market. As we stressed in the so-called “7 plus 7 Report”, this requires a balanced approach combining risk-sharing and market discipline. Concretely, this comprises the completion of the Banking Union, including a common deposit insurance scheme and an appropriate regulation of sovereign exposures, a deeper Capital Markets Union, as well as a modified fiscal framework. Such reforms have to be accompanied by sound and sustainable economic policies fostering innovation, inclusion, and economic growth, while making climate policy a priority.

The geopolitical challenges arising from shifting global powers imply that Europe and the euro area need to build a strong base at home in order to further advocate the preservation of the multilateral order.

The euro area is also facing a number of structural changes, related to the advent of cryptocurrencies, digitalisation, cyber security and the fight against money laundering.

Within its mandate, the ECB can contribute to addressing those challenges by embracing change and providing sound analysis and advice.

21. What do you see as the most important risks and challenges facing the ECB?

Looking at the short term, the euro area has enjoyed a long period of growth but the economy has started to lose some steam. Increased uncertainty in the world economy seems to be the critical factor behind these developments. Should any of the downside risks materialize, for example due to a new escalation of the trade conflict, a recession may be harder to avoid. However, the high degree of monetary accommodation makes such a scenario less likely.

In a longer-term perspective, the ECB will need to adjust to structural changes like any other agent in the economy. This most of all concerns digitalization and climate change, but also the structural decline in interest rates – a global phenomenon – on the back of ageing societies and transformations in production structures.

The combination of heightened risks to the outlook and structurally lower rates make the conduct of monetary policy more challenging. Given that key policy rates are already low, the space under the ECB’s conventional monetary policy instruments is limited.

Hence, the ECB’s monetary policy measures will have to be guided by a careful assessment of their benefits and costs, considering their effects on the economic and inflation outlook as well as their implications for financial stability. With a view on the long-term challenges, the ECB will have to discuss how it can contribute to dealing with structural changes within its mandate. The upcoming review of the ECB’s monetary policy strategy and operational framework provides an excellent opportunity to reflect on these issues.

Finally, the complexity of the environment also implies that communication to the public will need to play a larger role in the future. In some countries, low interest rates are seen very critically and the ECB is blamed for this development. The risk is that this undermines trust in the common currency over the longer term. In the past, communication has been directed mainly towards financial markets. In the future, communication with the wider public should play a larger role. Given the impact that monetary policy has on the people, they need to better understand both the role and the limitations of central bank policy. This also concerns the need for a better economic policy mix in order to foster the economic development of the euro area.


22. What are the risks related to Brexit for financial stability? How do you view the ECB’s role in addressing those risks?

The long and inconclusive negotiations on Brexit have caused a lot of uncertainty in the EU economy. This is likely to have depressed investment and economic growth in the United Kingdom, with some spillovers to the euro area. In spite of the extension of the UK’s membership until January 31, 2020, political uncertainty remains, and a no-deal Brexit still cannot be excluded. Such a scenario could generate significant market volatility and systemic repercussions cannot be fully excluded.

Central banks and financial institutions seem to be well-prepared for such a scenario so that the risk of a systemic event is considered to be small. The EU and national governments have taken safeguards to address possible disruptions, in particular for cross-border financial services. Critical issues are the continuity of contracts and clearing activities through CCPs.

The ECB has participated in this process and it should continue to monitor the developments closely and assess the risks to the euro area economy and the financial system. Banks and other private actors were requested to implement contingency plans and prepare for a no-deal. Safeguards should stay in place until there is full certainty on Brexit. In any case, the ECB maintains favourable liquidity conditions and an ample degree of monetary accommodation, and could take appropriate action to safeguard financial stability if funding and liquidity conditions were to deteriorate.

23. Do you think that the current economic governance framework encourages pro-cyclical fiscal policies? Does it set the right incentives for public investment? What kind of reforms to this framework do you deem necessary? What is your view on further European harmonisation in the field of corporate taxes?

An effective countercyclical fiscal policy is central for macroeconomic stability. In a currency union, fiscal policy is the main instrument to deal with asymmetric shocks, given that the single monetary policy is directed at the euro area as a whole and the exchange rate can no longer be used for this purpose. To this end, fiscal rules have to be flexible enough to allow for countercyclical policy while preventing excessive and unsustainable public debt and making the no bail-out clause (Art. 125 TFEU) credible.

Overall, the current situation looks benign. Many euro area countries have reached their medium-term budgetary (MTO) objectives as set by the Stability and Growth Pact, and there is no ongoing Excessive Deficit Procedure (EDP). However, the progress in reducing the level of government debt has been insufficient in some countries, as compliance with, and enforcement of, the fiscal rules has not been optimal. While sovereign bond yields have decreased substantially compared to earlier times, such developments may revert quickly in case of political or economic shocks.

All in all, the EU fiscal framework, including the rules of the SGP, has not fully fulfilled expectations. In addition to its excessive complexity, it has proven difficult to reliably estimate structural deficits in real time. Therefore, fiscal rules may be too stringent in bad times, while being too lax in good times. What is also clear is that the no bail-out rule lacks credibility because the costs of sovereign default would be substantial. Finally, the EMU lacks tools for risk-sharing and stabilization. All of these issues are linked: alluding to the theme of the “7 plus 7 Report”, market discipline cannot be credible because there is too little risk sharing to limit contagion and lower the costs of debt restructuring.

Reforms to the EU fiscal framework seem warranted in three dimensions. First, in terms of the rules themselves, the most prominent option proposed is to move towards a long-run debt target combined with an expenditure rule. Second, it seems crucial that governments raise the share of productivity-enhancing investment in their overall spending. Third, these reforms should be complemented by a euro area fiscal capacity to provide for risk sharing. Such a capacity could be designed as an incentive-compatible unemployment reinsurance scheme, but there are other options. The critical element is that a euro area level instrument helps to internalize spillovers across Member States, which are not taken into account by the Member States themselves.

Finally, initiatives aimed at introducing minimum corporate taxes could be useful to avoid overly aggressive tax practices and the erosion of the tax base. However, tax competition may still play a beneficial role and should not be turned off completely.

24. Do you think that the Euro area needs a European Safe Asset not only to help stabilise the financial markets and allow banks to reduce their exposure to national debt, but also as a way to facilitate the correct transmission of the monetary policy? How could this be achieved?

“Safe assets” have a number of benefits: they provide a benchmark interest rate for the whole yield curve, serve as a store of value and provide a cheap funding source for the issuer. Another key quality is that, if well-designed, they provide safety in times of crisis.

The conduct of non-standard monetary policy could benefit if it could rely on one euro area safe asset. A safe asset could also contribute to rendering the transmission of the ECB’s monetary policy more uniform across Member States by avoiding fragmentation. Finally, a safe asset that is not sensitive to sovereign risk developments in individual Member States could also help mitigate the negative feedback loops between sovereigns and domestic banks – as well as flights to safety – which were observed during the last crisis, and facilitate financial integration. This may then also clear the way for completing Banking Union because concerns about a regulation of sovereign exposures are less relevant in the presence of a euro area safe asset.

The previous financial crisis has led to a sharp reassessment of risks, effectively decreasing the supply of safe assets. At the same time, a variety of factors (e.g. new regulatory rules, such as liquidity requirements for banks, or demographic developments in the advanced economies) have raised the demand for safe assets. For these reasons, safe assets are seen as scarce in the current environment, and their scarcity may negatively impact financial markets and the banking sector, monetary policy implementation and economic growth.

A common safe asset could effectively mitigate the safe asset scarcity in the euro area, could be beneficial for the EMU architecture and could strengthen the international role of the euro. However, great care has to be taken in the design of euro area safe assets in order to avoid a mutualisation of risk, which would not be appropriate in light of the current structure of EMU as a union of sovereign states. The most prominently discussed proposals for safe assets are SBBS and e-bonds. While the first proposal relies on tranching, the second relies on subordination. Both proposals have their weaknesses, but they show that clever designs are feasible that do not lead to a mutualisation of debt. More work needs to be done.

While the ECB may provide analysis and advice on a safe asset, its introduction and design are not up to the ECB.

25. What is your view on the ongoing debate on the persistent high levels of public and private debt in the euro area? How do you see the possibility envisaged by the European Commission of a euro area Treasury to access financial markets on behalf of its members to fund part of their regular refinancing needs?

High private and public debt levels are one major vulnerability of the euro area. Today, the situation is slightly more benign than in the years after the crisis. Private debt-to-GDP ratios have come down from a peak level of 147% in 2015 to around 137% today, whereas overall euro area public debt-to-GDP ratios have declined to around 87% of GDP in 2018, down from 94.4% in 2014. But these magnitudes are still substantial.

Therefore, there is no reason for complacency. High public and private debt levels before the financial crisis proved to be a significant vulnerability in many Member States. Moreover, the overall improving picture masks the strong underlying heterogeneity. Private debt levels continue to be higher than what is considered sensible under the Macroeconomic Imbalance Procedure, and public debt levels are still higher than what is allowed under the Stability and Growth Pact in a number of countries, with several Member States having public debt ratios above 100% of GDP. Several Member States have not sufficiently used the preceding years with low interest rates and robust growth to reduce their public debt levels. This may pose a threat to the stability of the euro area if the situation worsens in the downturn.

A reduction of both public and private debt ratios is unavoidable. At the national level, this requires sound fiscal policies as well as the use of macroprudential instruments. In phases of consolidation, it matters which types of expenditures are cut. A more growth-friendly composition of public finances would imply shifting resources towards public investment. On the private side, it could help to put in place more favourable framework conditions to reduce private debt overhangs.

Most importantly, it requires a boost to economic growth to increase the denominator of the debt ratios. The implementation of productivity-enhancing structural reforms that ensure long-term prosperity are crucial in this respect. Fostering the Single Market is one important way to foster productivity.

National policies can be supported at the European level, by improving the incentives for national policymakers to pursue sound fiscal and economic policies. However, the creation of a treasury office for the euro area would be a very far-reaching step. It would require that further sovereignty was shifted from the national to the European level in order to maintain the unity of liability and control.

26. What are your views on the criticism that the ECB’s collateral framework is not gradual enough and relies too much on external credit rating agencies (CRAs)?

Collateral requirements are an important aspect of any of the ECB’s credit operations. In fact, this is mandatory under Article 18.1 of the ESCB and ECB Statute. Moreover, it is prudent for the ECB to require collateral to protect itself from the financial risk associated with these operations. The current collateral framework allows the ECB to accept a wide range of assets and applies specific haircuts to them, depending on a risk assessment. For this purpose, the ECB relies not just on external credit rating agencies, but also on in-house credit assessment systems by national central banks and internal ratings-based systems of counterparties. These seem to reflect underlying risks reasonably well.

At the same time, the ECB should continue to be supportive of initiatives to further enhance the transparency of external credit assessments, or of in-house credit assessments, because they may protect the ECB’s balance sheet even better.

27. How do you assess the recent evolution of the EUR/USD exchange rate?  To what extent should trade considerations play a role in the conduct of monetary policy?

Exchange-rate developments need to be monitored because they may affect inflation. The ECB does not target the exchange rate. This is in line with the international consensus and helps to avoid the harmful effects of currency wars. In other words, other than as an analytical input to understand the economic outlook, trade considerations should not play a role in its monetary policy decisions. Rather, the exchange rate should be left alone to be determined by market forces, in line with economic fundamentals, to allow fair competition and promote international trade.

28. How do you assess the achievements of the G20? What are your views on the current level of coordination between the main central banks?

Due to various and tight interlinkages among countries in the global economy, international cooperation is crucial to increase overall welfare. The trade conflict has shown how harmful it can be if multilateral agreements are replaced by “my country first”-policies. The current slowdown in the euro area is mainly related to external factors, which shows the importance of the stability of the global economy and financial system for the euro area. Such stability in turn requires strong international cooperation, including strong multinational organisations, to monitor and reduce imbalances, strengthen crisis management tools and analyse long-term trends affecting the global economic outlook.

In particular, the G20 and the Financial Stability Board have been a cornerstone in coordinating the economic policy response to the global financial crisis and shaping the reform agenda. New tasks of the G20 will include how to address global challenges stemming from trade and geopolitical uncertainties, digitalisation and innovation in payments.

The G20 also provides an important format for interactions among central banks, alongside the G7 and the Bank of International Settlements (BIS). In this way, they provide a conduit to exchange lessons learnt, which can in some cases point to common approaches.

29. Should the ECB take concrete steps to boost the euro as an international currency? If so, what measures do you envision?

Boosting the international role of the euro would likely have important implications for the conduct of monetary policy. These include a potentially stronger transmission of monetary policy decisions, a weaker impact of exchange-rate developments on inflation, and effects on the level of the exchange rate and sovereign bond yields. Overall, ECB findings points to a net positive effect of a stronger international role of the single currency on the euro area economy.

The international role of the euro would benefit from a more integrated Economic and Monetary Union with stronger capital markets. Stronger resilience in the eyes of international investors, on the back of a fully developed Banking Union and sound national fiscal positions and economic structures, would also support the international role of the euro. This could be further underpinned by the introduction of a safe asset.

30. What do you see as the main challenges and opportunities for central bank communication in the period ahead?  

By guiding expectations and promoting trust, communication supports the effectiveness of the ECB’s policies. The need for sound communication on the part of central banks grew considerably during the crisis and with the deployment of more complex, non-standard instruments. In fact, with forward guidance, communication has become a monetary policy instrument of its own.

The spotlight on central banks and the complexity of the new instruments created demands to step up communication not just with financial markets, but also with the public. Importantly, it requires and will continue to require a strong accountability of central banks to their parliaments. To satisfy demands for greater transparency, the ECB has started to publish its monetary policy accounts, and it has enhanced the disclosure of its asset holdings.

Reaching out to a wider set of actors means that the institution needs to strive to explain its actions in simpler ways. In doing so, it will also have to show how they relate and make a positive difference to citizens’ daily lives. This also means engaging in discussions on how the ECB can, within the remit of its mandate, contribute to emerging challenges.

31. How would you assess the monetary policy spillovers, in particular from the United States, for the conduct of monetary policy in the euro area?

All advanced economies are closely connected through trade links and global financial markets in which assets of all countries are traded. This implies that the monetary policy of the United States, by affecting US financial markets and the exchange rate, also affects the euro area. These impacts are particularly visible in financial markets but are present in all other markets as well.

The ECB should look at spillovers when assessing growth and inflation prospects for the euro area and factor them in the formulation of monetary policy. It should always be clear, however, that the exchange rate is not a target for monetary policy and that the ECB is focused on maintaining domestic price stability in the euro area.

32. The German Council of Economic Experts argued, highlighting the case of Greece, that an exit of a Eurozone must be an option so that the struggling country cannot blackmail other Eurozone members. What is your opinion? How would you define European solidarity in that context? How would you assess the likely effects of uncertainty at the financial markets?

The euro has been constructed as being irreversible. This irreversibility, together with the singleness of monetary policy, distinguishes the euro from other exchange rate arrangements like currency boards or informal currency unions. As long as it is credible, it protects the euro area against speculative attacks. The exit of one Member State from the euro area could seriously damage such credibility and could give rise to speculation against other Member States. Therefore, the exit of a Member State should not be seen as a viable option.

C. Financial stability and supervision

33. What are your views on the need to ensure a strict separation between monetary policy and banking supervision and what are in your view the reforms that would enhance and favour such separation?

The decision to assign supervisory tasks to the ECB when the SSM was established was to a large extent driven by the need to establish European supervision within the constraints of the current Treaty. It enabled the SSM to take up its activities quickly thanks to the existing organization and capabilities of the ECB and ESCB.

A priori, it is not clear whether a separated regime is to be preferred to a combination within one institution. On the one hand, the combination of monetary policy and banking supervision may bring about information advantages. Lender of last resort activities and monetary policy may be improved if they can be based on supervisory information. This may foster financial stability and improve monetary policy. On the other hand, the objectives of monetary policy and banking supervision may be conflicting, such that one or the other objective could be compromised if combined within one institution. Moreover, reputational risks may occur when supervisory failures affect the credibility of monetary policy.

The design of the SSM takes a middle way by combining monetary policy and banking supervision within one institution, while maintaining a separation principle. This principle ensures the organisational separation of staff, confidentiality rules for information sharing, as well as different decision-making procedures between the banking supervisory and monetary parts of the ECB. I consider these safeguards very important and appropriate. Nevertheless, it will be crucial to check regularly whether the current system could be improved. The working of the separation principle should be paid special attention. So far, I have not seen any indication that changes to the prevailing regime are needed.

34. What is your view on the current institutional set-up of the ESRB under the roof of the ECB with regard to its concrete achievements in macro-prudential oversight?  

The creation of macroprudential regulation and supervision was one of the key steps in reforming the financial architecture after the global financial crisis. The European Systemic Risk Board (ESRB) plays a central role in the European supervisory architecture and has established itself as a useful institution for monitoring the financial stability risks emanating from macroeconomic developments and the financial system.

The existing institutional structure, with the General Board as the primary decision-making body complemented by the Steering Committee, the Secretariat, the Advisory Technical Committee and the Advisory Scientific Committee, has overall proved to be successful. In addition, the combination of academic expertise, the use of ECB research and analysis and the participation of a wide range of financial policy makers have proven to be very helpful to the functioning of the ESRB. Nevertheless, the ESRB may benefit from larger resources and a more direct access to data in order to be able to carry out its tasks with a greater degree of independence. Moreover, while close collaboration with the ECB is desirable, a greater independence could ensure that threats to financial stability are given sufficient consideration even if they derive from monetary policy itself.

In terms of its concrete achievements, the cross-sectoral approach of the ESRB, including banks, insurance companies as well as financial markets and market infrastructures, has been very effective. Their analysis and publications have provided an important basis for the design of macroprudential policy in the EU. Its identification of emerging and existing systemic risks has provided the basis for numerous recommendations, warnings and opinions, calling for action by the national authorities.

35. How can we address the high levels of the stock of non-performing loans as well as the risks in the flow of non-performing loans? How do you assess the problem of non-performing loans in the balance sheets of medium and small credit institutions? How do you see the ECB’s/the SSM’s role in addressing this issue?  

The ECB has played an important role in the efforts to reduce non-performing loans (NPLs), and the Single Supervisory Mechanism (SSM) has made the reduction of NPLs a priority early on. A first important step was the harmonization of definitions of NPLs across the euro area. Through its microprudential supervision, the ECB has set out clear expectations how banks should address the problem and has successfully pushed banks to implement NPL reduction strategies. At the inception of the SSM, NPLs of banks stood at almost 1 trillion euro. Helped by the benign economic environment and determined supervisory action, the stock of NPLs has gone down to 560 billion euro.

However, the levels of NPLs still differ markedly across Member States, and especially in most of the former crisis countries, the NPL ratio is still above pre-crisis levels. Therefore, a further reduction of NPLs remains an important task. In addition, it is important to prevent the future build-up of NPLs. The new rules regarding the faster provisioning of new NPLs are pointing in the right direction.

So far, too little attention has been paid to the issue of NPLs at less significant institutions, which are not directly supervised by the ECB and are hence not subject to the ECB’s guidance on NPLs. Given that the comprehensive assessment before the start of the SSM was focused on significant institutions only, there is also less transparency regarding the extent of the problem. Therefore, a comprehensive assessment of LSIs may be considered, especially when it comes to judging whether less significant banks are fulfilling the prerequisites for moving forward in the Banking Union.

In any case, smaller banks are also subject to the Pillar 1 backstop in the revised CRR to ensure adequate provisioning levels for new NPLs. This rightly reflects the need for a level playing field for all banks in the Banking Union, including the less significant institutions, while respecting the principle of proportionality.

36. How do you assess the high level of level 2 and level 3 assets in many bank balance sheets? Are these assets properly taken into account by the current supervisory framework?

The volume of level 2 and level 3 assets in bank balance sheets is substantial. In the second quarter of 2019, according to ECB supervisory statistics, level 3 assets of SSM banks amounted to 194 billion euro and level 2 assets to 3,174 billion euro. In light of such magnitudes, valuation risks from level 2 and level 3 assets should be subject to close supervisory scrutiny. The SSM appears to be sharing this view as trading risk and asset valuation continue to be a supervisory priority for the year 2020.

The accounting treatment of assets that do not have reliable market prices has been an issue for a long time. Level 2 assets (or liabilities) are not frequently traded but still allow for the determination of a fair value based on observable inputs. This proves to be very difficult for level 3 assets, which are “marked to model” based on unobservable inputs and assumptions. This implies that there is a high degree of uncertainty regarding the appropriateness of their valuation. It does not necessarily mean that they are by definition dangerous or a threat to financial stability. However, given the difficulties in the valuation of level 2 and level 3 assets, continued monitoring is warranted.

37. What are your views on the regulation of shadow banking entities? Do you see regulatory and supervisory loopholes that should be addressed by legislators in the short term?  

After the financial crisis, non-bank financial intermediaries (NBFIs), in particular asset managers, have gained importance. In principle, a greater diversification of the financial system is desirable as financial systems dominated by banks have shown little resilience in the crisis. The growth of non-bank financial intermediaries hence partly reflects a desired shift towards more market-based financing, which may help to increase the overall resilience of the real economy.

However, there has been a concern about regulatory arbitrage as risky activities may have shifted from the more strongly regulated banking sector into “shadow banks”. While it is not true that other parts of the financial systems are unregulated, it has been only recently that the focus has shifted towards potential systemic risks emanating from these sectors. The Financial Stability Board (FSB), the ESRB and the ESMA have conducted useful work to identify and deal with systemic risks in NBFIs, especially with respect to liquidity risks and the risks from leveraged institutions. Further work is needed to better understand spillovers from NBFIs to other parts of the financial sector, including the traditional banking sector.

These insights could be useful inputs for identifying and closing gaps in the micro- and macroprudential regulation of the NBFI sector.

38. What are your views on the steps towards the completion of the Banking Union with a European Deposit Guarantee Scheme and a fiscal backstop, including the necessary implementation of existing Banking Union legislation?  

A European Deposit Insurance Scheme (EDIS) is an integral and indispensable part of the Banking Union. The overarching goal of Banking Union was to mitigate the tight link between sovereigns and banks. Common supervision and resolution are desirable steps in this direction. However, important gaps remain. In this light, I strongly welcome the renewed momentum to agree on a Roadmap for EDIS.

Through national deposit insurance schemes, there is a close connection between banks and their national sovereigns as the credibility of deposit insurance ultimately relies on an implicit fiscal backstop. Hence, the credibility of deposit insurance hinges on the state of the sovereign, just as the sovereign may be affected negatively by distress in the banking sector. National deposit insurance acts as an impediment to banking sector integration as it sets incentives for ring-fencing in crisis times. A fragmented banking sector makes it more difficult for banks to exploit the benefits of the large European market, which has become even more relevant with the advent of digital business models.

EDIS should be designed as a reinsurance system with permanent national compartments, which have to be tapped first before accessing European funds. Insurance premia should depend on bank- and country-specific risk factors. In the future, the Roadmap should also lead to a common public backstop for EDIS, which would be the final step needed to sever the nexus between national banking systems and their sovereigns.

EDIS will need to be accompanied by further regulatory steps. This comprises, most importantly, an appropriate regulation of sovereign exposures to avoid that sovereign default risks can be shifted to the European level through common deposit insurance. This could take the form of risk-based sovereign concentration charges, which set in only above a certain level of sovereign exposures towards a particular sovereign.

Moreover, the completion of Banking Union requires further risk reduction, for example a further decrease in NPLs and the build-up of bail-inable capital (TLAC and MREL). A European safe asset (discussed above) could help to facilitate the transition to the new regime by offering a safe and well-diversified asset for banks, and may mitigate concerns regarding the effects of a changing regulatory treatment on the stability of sovereign debt markets.

While the new resolution regime has passed its first tests, there also remain gaps in the resolution framework. Given the current system, only the larger resolution cases are dealt with at European level, while the less systemic cases are in the responsibility of the Member States. However, national bank insolvency regimes are not harmonized, implying that there does not exist a single resolution regime but de facto 19 separate ones. Therefore, the harmonization of national bank insolvency regimes should be high on the agenda. Another issue concerns the provision of liquidity in resolution. While the agreement on the fiscal backstop to the Single Resolution Fund (SRF) has been an important step, the SRF still won’t be able to deal with liquidity demands because these easily reach a scale that goes well beyond the size of the SRF including the backstop.

39. What risks related to leveraged loans do you see for financial stability and how should they be addressed?

Against a backdrop of low interest rates, we have seen investors search for higher yielding investments. Leveraged loans are granted to already highly indebted companies or individuals with a comparably poor credit history. Thus, they carry an intrinsically higher credit risk and pay higher returns.

According to ECB Banking Supervision’s May 2019 Newsletter, the 18 most active banks in this market among those supervised by the ECB had exposures of 321 billion at the end of last year. This is still substantially lower than the leveraged loan market in the US. But the ECB has repeatedly emphasized the danger of mispricing and of weakening underwriting standards in the leveraged loan market. In 2017, the ECB therefore issued a Guidance on leveraged lending and has included leveraged finance in its 2020 supervisory priorities. In fact, in a recession, leveraged loans could quickly show increasing default rates. There is also a potential systemic risk element, as investors are highly interconnected and banks have indirect exposures, including through CLOs (Collateralized Loan Obligations).

40. Which challenges would you foresee for the ECB if the European Stability Mechanism (ESM) was to be transformed into a European Monetary Fund (EMF)? Which role do you attribute to financial market discipline in pricing sovereigns?  

A centrepiece to crisis management in the euro area was the establishment of the European Stability Mechanism (ESM) and its precursor, the European Financial Stability Facility (EFSF). Its total disbursement of 295 billion euro of financial assistance since 2010 underlines the important role that the ESM has played.

Despite its effective role, the crisis also revealed that the ESM’s functioning can be further improved. These reforms are going in two directions. First, there is a set of reforms, currently being discussed, that seek to bolster the ESM’s governance and complement its toolkit. This concerns a stepped up role of the ESM in financial assistance programmes and modifications of the ESM precautionary credit lines, which have never been used so far. (This does not necessarily mean that they are ineffective – OMT has not been used either but clearly has had stabilizing effects.) Second, there is a set of reforms whereby the role of the ESM is being altered to provide support to other parts of the euro area architecture. This includes, most notably, the role that the ESM will play as the backstop to the Single Resolution Fund, thereby strengthening the bank resolution framework.

Given the foreseen improvements in both dimensions, a political agreement on ESM reform in December 2019, followed by national ratification processes in 2020, would be most welcome.

However, regarding the transformation of the ESM, I believe that it would be a misnomer to refer to a transformed ESM as a “European Monetary Fund”, as this would not aptly describe the ESM’s functions.

Sound fiscal policies are essential to ensure that sovereign debt levels remain sustainable and that national governments have enough fiscal space to respond to economic crises. Rising risk premia can serve as a warning that the sustainability of sovereign debt is threatened. However, past experience has shown that markets do not always function perfectly and that there can be market failures especially in crisis times, leading to harmful boom-bust dynamics. Therefore, any fiscal framework should include aspects of market discipline in order to prevent the build-up of fiscal imbalances, but should also contain an effective crisis management framework. Both are fundamental to the stability of the euro area.

41. What is your assessment of the involvement of the ECB in the context of financial assistance programmes? How do you see evolving in future a potential ECB involvement in financial assistance programmes and in post-programme surveillance?

In the euro area crisis, the ECB was closely involved in financial assistance programmes. At the same time, it had no formal decision-making power for actions and decisions made in the programme context and did not co-sign the Memoranda of Understanding with the countries accessing financial assistance. To recall the legal underpinning: both the Two-Pack Regulation, and the ESM Treaty allocate to the ECB the task to provide advice to the European Commission in its work related to financial assistance programmes. The ECB involvement in post-programme surveillance also ensures that the ECB is in a position to assess implications for its tasks and to provide its expertise for all parties involved.

However, in my view, the ECB’s participation in financial assistance programmes and in post-programme surveillance could potentially raise conflicts of interest – even though its role is only an advisory one. Moreover, the ECB’s activities in such programmes should be linked as closely as possible to its mandate.

For that reason, it is to be welcomed that the ECB has restricted its area of operations by focusing more on macroeconomic and financial sector issues. This allows the ECB to best use its expertise and leverage on financial sector policies in programme countries, thereby facilitating the conduct of monetary policy.

42. How do you assess the implementation of the bank resolution mechanism in the EU? What are your views on ‘too-big or interconnected to fail’ institutions, savings and cooperative banks, and the overall issue of the profitability of the banking sector in the EU, and what is your view on the way forward for its architecture in order to fulfil the needs of the real economy and long term financing?

Making banks resolvable without causing systemic disruptions and without using taxpayers’ money was one major goal of post-crisis reforms. To this end, the EU created a new bank resolution regime based on the Bank Recovery and Resolution Directive (BRRD), which entered into force in 2015 (its bail-in procedures were applicable as of January 1, 2016). In the euro area, this was institutionalised through the Single Resolution Mechanism (SRM), including the Single Resolution Fund (SRF). The fundamental paradigm shift is to replace the common practise of bank bail-out by a creditor bail-in.

The new resolution framework is a big step in the right direction. However, the past years have shown that it is not yet sufficient. While we have seen several bail-ins of junior (i.e. subordinated) debt, senior debt has typically been spared. National insolvency regimes could be used to circumvent the stricter European rules. And it became clear quickly that the SRF was too small to be able to deal with larger crises, which led to the proposal of a fiscal backstop.

Therefore, the resolution regime has to be developed further, striving for a harmonization of national bank insolvency regimes and setting up a fiscal backstop as well as a facility for liquidity in resolution.

Experience has also shown that bail-in can be controversial even in non-crisis times at comparably small banks. This suggests that a bail-in at a large bank in the middle of a crisis may be much more difficult. This potential lack of resolvability of larger banks (due to their size – too big to fail – or their interconnectedness– too interconnected to fail) should be countered by imposing much higher capital requirements on banks that are difficult to resolve. The build-up of additional loss-absorbing capacity as well as additional capital buffers for systemically important banks has already contributed to address this problem. But in my view, the additional capital requirements for systemically relevant banks are still too small.

Profitability of euro area banks is relatively low in international comparison. This is a concern from a financial stability perspective as banks with low profitability have difficulties to build up capital through retained earnings. It may also make it more difficult for banks to compete with new market entrants in the digital economy, as low profits hamper investments in digital business models and IT systems, which further reduces banks’ competitiveness.

Low profitability is not a recent phenomenon, but it dates back to the years before the crisis, pointing to structural causes. Cost-income ratios tend to be high and have partly even increased in recent years. This is partly due to fierce competition, pointing towards a potential overbanking. In fact, this is partly the result of not having been willing to let banks exit the market after the financial crisis. With most banks having been rescued and new competitors including non-banks entering the market, profit margins tended to decline, in spite of the ongoing consolidation process in the European banking sector.

In order to reduce overbanking, further consolidation seems unavoidable. In addition, weak banks should be allowed to exit the market rather than keeping them alive with taxpayers’ money. In a European banking market, cross-border mergers could be an attractive option. However, such mergers are made difficult by the practise of ring-fencing domestic subsidiaries of foreign banks. A completion of Banking Union would contribute to mitigating the frictions in cross-border mergers. This would help to strengthen banks and therefore contribute to enabling the banking sector to fulfil its task of financing the real economy.

43. How could money laundering, tax avoidance and terrorist financing be addressed more effectively across the Banking Union?  How should money laundering risks be taken into consideration when the ECB assesses banks financial stability? Is there a need to centralise anti-money laundering (AML) supervision in a single EU agency or mechanism?  

Money laundering has appeared as one of the biggest operational risks in banking markets. When banks are involved in money laundering, this is not only a criminal offence, but it can also lead to a bank’s failure, as confirmed by recent cases.

In the financial crisis, we learnt that financial risks do not stop at national borders and responded with the set-up of an integrated system for European banking supervision. A similar step might be necessary to improve the effectiveness of the AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) framework. Illegal financing transactions are inherently a cross-border issue, which has to be solved at supranational level. The current system still suffers from too much fragmentation and does not do justice to the reality of an integrated European banking market. Future steps should include not only the set-up of a centralised EU body responsible for AML/CFT supervision but also further regulatory harmonisation, notably by transforming the AML Directive into a Regulation.

Further, the EU and the ECB also have to develop a consistent approach how money laundering and terrorism financing risks can be integrated into prudential supervision. When banks engage in illegal activities, this is also a reflection of weak governance frameworks and inadequate compliance, control and risk management frameworks. The ECB has also explained in some detail what they have done to strengthen their engagement in the AML and CFT area.

However, AML is not a prudential task, which means the prudential supervisor does not have direct access to information but has to rely on information provided by other authorities. The recently signed cooperation agreements between the ECB and AML authorities at national level to allow for a timelier sharing of information represent a very positive development.

The Council Action Plan also sets out a number of important non-legislative actions to address the problems and the EBA Opinion sends a clear message on the importance of money laundering risks for prudential supervision across the Single Market.

44. Do you think that non-euro area Member States should fulfil additional conditions before becoming members of the euro area and thereby members of the Banking Union, such as controlling money laundering risks effectively, demonstrating comparably stable property markets, controlling corruption effectively?

As discussed above, the ECB and the European Commission publish regular convergence reports, in order to assess how far each non-euro area country has progressed towards the criteria laid down in the Treaty and whether this convergence is sustainable. Since euro adoption also implies participation in the SSM, countries that wish to join the euro are asked to enter into close cooperation with ECB banking supervision prior to adopting the euro. This already comprises an assessment of the national legal framework to allow the ECB to exercise its supervisory tasks as well as a comprehensive assessment of the banks that will be supervised directly. It is important that these processes are accompanied by intense exchanges with all parties involved. This may also include discussions on non-prudential aspects, such as anti-money laundering, because they can have a significant impact on banks’ risks.

45. Is deeper financial integration always consistent with the objective of financial stability? Do you believe potential cross-border bank mergers reinforce the too-big-too-fail problem? What should be the goals of the Capital Markets Union (CMU)?  

The relationship between financial integration and financial stability can go in both directions.

On the one hand, financial integration may impair financial stability. When financial markets are strongly integrated, their ability to propagate risk is also increased. This promotes financial contagion and, in turn, increases the likelihood of systemic crises. This depends, however, on the resilience of cross-border capital flows. Research has shown that equity flows tend to be more resilient than debt flows, long-term more than short-term flows, and retail more than wholesale flows.

On the other hand, by promoting risk sharing, financial integration could enhance the resilience and stability of the financial system. It could also raise productivity and economic growth by promoting a more efficient allocation of resources across countries. Finally, from a central banks perspective, stronger cross-border integration would improve the monetary transmission mechanism.

This is why the Banking Union and the Capital Market Union projects are so important for the well-functioning of the Economic and Monetary Union. In fact, completing these projects will make it possible to achieve a very hard to find balance between higher integration and greater financial stability. For these benefits to materialise, it is important to have a well-functioning institutional set-up at European level.

For the Banking Union, with both the supervision and the resolution of banks shifted from national to European level, it is now possible to unblock the path towards a truly integrated European banking market, while managing at the same time the risks associated with dealing with large cross-border banks in a crisis. In a truly European banking market, cross-border mergers would become the norm. Since such institutions could easily become very large, there could be a too-big-to-fail issue. But rather than prohibiting such mergers, these banks should be subject to stricter regulation and supervision, for example, in the form of higher capital requirements. It should also be kept in mind that, relative to the European banking sector, even the merged banks would be comparably small. Without completing the Banking Union, there will not be a truly European banking market.

In a similar vein, a genuine CMU would reduce the reliance on banks, encouraging market-based sources of finance. This would increase the resilience of the financial system and enhance the functioning of private risk sharing channels when shocks hit the economy. In order to achieve these goals, the main focus should be on resilient forms of funding, in particular equity flows. To this end, an ambitious CMU agenda is important. This project should translate into concrete policy proposals, which are effectively implemented, as changing the financial landscape is certainly not an easy task. The progress made so far should certainly be welcomed, but more remains to be done. It is important to have an ambitious plan to strengthen supervisory convergence across the EU. Eventually, a centralized supervisor may be needed to consistently implement a strengthened single rulebook for EU capital markets. Moreover, harmonizing national insolvency frameworks has to be further pursued. Finally, in order to foster equity financing, the debt bias in taxation should be addressed.

46. A number of significant private and public sector bonds in Europe are characterised by negative yields. Does this have any financial stability implications and if so how should they be addressed?  

The current low yield environment is putting pressure on financial institutions’ profits, reinforcing underlying structural problems. In addition, it gives rise to search-for-yield behaviour, which may lead to a compression of risk premia. The low-for-long environment threatens the business models of traditional financial intermediaries.

For banks that are active in the traditional banking business, the main issue is not the level of interest rates but the slope of the yield curve. Moreover, it matters to which degree negative rates can be passed on to the banks’ customers. In general, one can discern an increasing maturity mismatch in the banking sector, which also exposes these banks to significant interest rate risk. This risk is not captured by Pillar 1 of the Basel regulation and should therefore be addressed through Pillar 2 measures.

In order to pay for obligations and defined-benefit schemes that stem from past commitments, pension funds and life insurance companies need to have a high enough return on their investments, which can be difficult in an environment of low nominal rates. The mechanics behind this are that, when yields decline further, the discount rate applied to the future cash flows falls and this increases the present value of both assets and liabilities. But the increase is typically more pronounced for the latter. For EU insurers, liabilities tend to have a duration of 11 years on average, while assets have a duration of around 6.7 years. Against that backdrop, low yields can indeed be challenging for insurers and pension funds and have made many of these firms to shift towards defined-contribution schemes.

However, both insurers and banks have also profited from the fact that low interest rates have positively affected economic growth and have helped reducing risks in the economy. For instance, lower unemployment and a stable inflation outlook reduce uncertainty with respect to household incomes and savings, which then facilitates the sale of new life insurance and pension fund products. The same forces are also beneficial for the risks on banks’ balance sheets, mainly by reducing loan defaults.

All in all, the ECB’s policies impact on the financial sector thus has to be analysed rather carefully and in a balanced way. In the end, it is important to remember that the ECB is not responsible for ensuring the profits of the financial sector, but to ensure that the sector acts as a conduit for monetary policy and price stability. Its policies in fact are partly aimed at creating incentives for financial actors to search for riskier and illiquid assets, to help ease financing conditions for non-financial corporations.

One has to be aware that this can also contribute to building up risks and vulnerabilities in banks’ and non-banks’ balance sheets, which in turn calls for the application of macroprudential tools in the banking sector and the development of such a framework for the non-bank sector, including for insurance companies.

47. What are your views on the current ECB policies with regard to the prevention of conflicts of interest within the ECB? Are any changes necessary?

The ECB’s main asset is trust. Therefore, it is of utmost importance that it respects the highest standards in terms of integrity, accountability and transparency. This should apply at all levels, i.e. to its decision-making bodies (Governing Council and Executive Board) as well as to the entire staff of the ECB. The ECB should continuously work on its ethical standards, and should strive to reflect best practices in its internal ethical framework, while at the same time taking into account the ECB’s specificities as a central bank, a banking supervisor and an EU institution.

My impression is that the ECB has substantially improved its rules to prevent conflicts of interest. For instance, earlier this year the ECB adopted a Single Code of Conduct, which applies equally to members of the Governing Council, the Executive and Supervisory Board. In understand this was partly a reaction to the feedback received by the European Parliament, the recommendations of the European Ombudsman as well as independent reports published by European NGOs.

D. Functioning of the ECB and democratic accountability and transparency

48. What will be your personal approach of the social dialogue at the ECB?

The ECB is an attractive employer with generally good working conditions. However, I assume the working environment is at the same time very demanding. For the success of an institution, I consider it very important that the employees are satisfied with their working conditions. If that is not the case, there needs to be an open and constructive dialogue between staff, including their representatives, and leadership, and I will be happy to participate in this. Since the ECB is committed to providing high quality output, it also has to ensure a high quality working environment for its staff. As I understand, the ECB has already taken measures to improve the workload, working time and flexibility arrangements of its staff, which is to be welcomed.

49. The European Parliament plays a major role in the accountability of the ECB. What conclusions do you draw from the comparison with other jurisdictions? (e.g. US Congress/Fed vs European Parliament/ECB vs UK Parliament/Bank of England)? What measures and future reforms would in your view reinforce the democratic accountability of the ECB towards the European Parliament?  

The need for independent central banks is well-established. However, this requires a counterweight in the form of accountability. For this purpose, the ECB explains its decisions and the underlying reasoning both to EU citizens and to their elected representatives. On this basis, these can form a judgement on the ECB’s performance against its objectives, in particular that of maintaining price stability, which are specified in the Treaty on the Functioning of the European Union (TFEU).

Under the Treaty, the ECB is primarily accountable to the European Parliament as the representation of EU citizens, but also has to report regularly to the Council of the EU, which represents Member State governments. According to Art. 284(3) TFEU and Art. 15(3) of the ESCB Statute, the accountability framework has the following elements:

- an annual report on the activities of the ESCB and on monetary policy to be addressed to the European Parliament, the Council, the Commission, and the European Council and presented by the President of the European Central Bank to the Council and the European Parliament;

- possible hearings of the President of the European Central Bank and the other members of the Executive Board by the competent committees of the European Parliament at the request of the European Parliament or on their own initiative.

In practice, the ECB’s accountability channels have developed well beyond the Treaty requirements and include the following:

- quarterly hearings of the ECB’s President in the Committee on Economic and Monetary Affairs of the European Parliament, which are available as webcasts and for which a full written transcript is published;

- replies to written questions by the Members of the European Parliament to the ECB, available for download on the ECB’s website;

- written feedback to the European Parliament’s resolution on the ECB Annual Report, published on the ECB’s website.

Moreover, the ECB’s accountability for its banking supervision tasks is subject to a specific regime laid down in the Single Supervisory Mechanism (SSM) Regulation.

This broad accountability framework ensures that the elected representatives have the chance to gain information and express criticism. This is an essential foundation of the legitimacy and effectiveness of central banks in the pursuit of their mandates.

While international comparisons are challenging, there are no major differences in the degree of accountability of the ECB, the Bank of England (BoE) or the Fed as regards parliamentary exchanges according to the literature. These include quarterly public hearings in front of the competent committee. One difference is that the ECB President also appears once a year in plenary to discuss the ECB Annual Report. Unlike the ECB and the Fed, the BoE Governor is accompanied at committee hearings by other members of the Monetary Policy Committee.

Over and above this formal accountability framework, I see a responsibility of Executive Board Members to regularly present to the general public. Media presence may also play a role as a tool to communicate to the wider public. I would see this as part of my personal communication (and accountability) strategy.

50. What will the ECB concretely do to have gender-balanced shortlists for ECB top positions in the future and enhance overall more gender diversity in the ECB, given that at present only two out of 25 Members of the ECB governing council are female? How do you personally intend to improve gender balance within the ECB? When do you expect first results of your actions in this regard?

Promoting gender equality is a major objective in society, including central banks. Research has shown that diverse teams produce better outcomes, and there is no reason to believe that this should be different in central banking. Therefore, fostering gender equality should be high on the ECB’s agenda.

Central banks are facing the difficulty that a severe underrepresentation of women is found not only in central banks but in the entire economics profession. This is why fostering equality of opportunity has to start at an early career stage. Programs trying to attract women early on seem to be particularly promising. Therefore, I enthusiastically support the ECB’s new Women in Economics Scholarship. It is one example how to support women’s career development from the beginning. I would be happy to use my knowledge of and network in the academic context to develop further programs in this direction.

At the same time, it is important to understand the reasons behind gender inequality. Some research shows that implicit biases may play an important role, meaning that women are perceived to be less competent by both men and women due to particular types of behaviour. To counteract such biases, trainings of recruiters may be useful to raise awareness of potential distortions. There is also a lot of evidence that role models can be useful to motivate young women to strive for a career. This implies that the effect of hiring decisions goes well beyond the person in question. Finally, one could consider a policy that no member of the Governing Council participates in purely male policy panels. I have seen other institutions following such a policy. Of course, such a commitment could also be made on an individual basis.

Overall it seems important to make it a strategic priority to attract and develop female talent at all levels, and I wholeheartedly support such a strategy.

At an organisational level, building and leveraging gender diversity is not easy and there are no shortcuts, but we have to keep working on it. It is important that the ECB continues to attract and develop female talent at all levels.

It should be stressed that the ECB has limited impact on the appointments of national central bank governors. Currently, all of them are male. The Governing Council should clearly state that gender equality is an important objective and should be improved also in the Governing Council.

The ECB should also promote other aspects of diversity, ranging from nationality to ethnicity to educational backgrounds and also including the diversity of thought. Diverse and inclusive teams tend to be the best performers, as they help to avoid group-think. Indeed, it is of little help if an institution’s staff blindly follows what is perceived as the “house opinion”. Instead, there should be processes allowing for internal exchanges of views.

51. How do you see possible improvements for the ECB’s accountability vis-à-vis the European Court of Auditors (ECA) in terms of its operational efficiency? Where do you draw the line for the ECA’s mandate?

Like any other public institution, the ECB should ensure that it is operationally efficient, that it does not waste what is ultimately taxpayers’ money, and that its operational structures comply with its mandate. It is thus most welcome that the ECB’s operational efficiency is assessed regularly by the European Court of Auditors (ECA).

However, the substance of the ECB’s monetary and other policies is by definition the role of the ECB. These areas are not part of the auditing mandate of the ECA. In my view, the ECA has the highest value added if it looks at the efficiency with which the ECB conducts the processes to reach its decisions.

52. Do you think the ECB should apply the standards of the new Directive on the protection of persons reporting on breaches of Union law internally? When do you expect the ECB to establish specific procedures for protecting whistle-blowers?  

My understanding is that the ECB’s Executive Board has identified the enhancement of its whistle-blowing framework as a strategic priority, and stated that this also presents an opportunity to consider the standards set by the new “Whistle-blower Directive”, alongside best practices, policies and processes of other institutions. Safeguarded reporting channels and protection of whistle-blowers are vital to ensure risk management and improve the working culture.

53. What do you think about the fact that the Council in the past once ignored the opinion of the European Parliament regarding the appointment of a member of the Executive Board of the ECB? Will you accept your appointment as Executive Board member if the European Parliament were to vote against it?

The European Parliament plays an important role in holding the ECB accountable. Without such accountability, there could not be central bank independence. Therefore, the involvement of the European Parliament in the appointment process of Executive Board Members is crucial.

I greatly appreciate the exchange with the European Parliament as an important part of the appointment process and I hope for a positive assessment of my competence and suitability for the position of ECB Executive Board Member. This would form the basis for an open and trustful relation going forward.

54. Do you think it would be appropriate for you or other senior ECB staff to participate in the 'Group of Thirty' of central bankers and financial industry leaders or similar groups or associations?  

Every representative of the ECB should follow ethical standards at the ECB, which in turn should be in line with international best practices.

Of course, there can nevertheless be the need to interact with a wide range of stakeholders, including public and private sector representatives in order to exchange views and to share information. In fact, this can be crucial to be able to fulfil the mandate.

The Single Code of Conduct adopted by the ECB in 2019 has improved the management of potential conflicts of interest by introducing specific rules for relations with various interest groups. All Executive Board members should, at all times, and in particular in their interactions with interest groups, be mindful of their independence as well as their professional secrecy obligations. I will certainly stick closely to the rules laid down in the Single Code of Conduct.

55. In the past, the ECB has launched initiatives such as AnaCredit and the European Distribution of Debt Initiative (EDDI), which have not been at the core of the ECB’s mandate. How do you see the ECB’s role in such initiatives and where do you draw the line with regards to the legislator’s prerogatives?  

As a researcher, I am well aware that data are of the essence. In particular, large micro-data databases allow shedding lights on new economic and financial linkages by expanding information to any level of disaggregation needed. It is also possible to carefully track the impact of a particular shock to the economy.

Through a better understanding of the underlying mechanism, high quality data allow policy makers to make better decisions. The better the data, the greater the knowledge, and the better will be the resulting policy decisions.

This, of course, also applies to the ECB. This is why the Statute requires the ECB to collect statistical information that is necessary to undertake its tasks. AnaCredit will contain detailed information on individual bank loans in the euro area. I can see how, thanks to such detailed information, it would be possible to sensibly upgrade the ECB’s ability to understand the credit dynamics in the euro area economy. This, in turn, will help the ECB when taking monetary policy decisions.

The Treaty mandate of the ECB and the Eurosystem with regard to financial markets allows for the possibility of undertaking regulatory initiatives in payment systems. In this context, the ECB is exploring the possibility to support the harmonised issuance and distribution of euro debt instruments in the EU (the EDDI initiative).

I believe that the ECB should – and as far as I know, did for the two cases – collect views and input from key stakeholders on statistical and market infrastructure projects. Moreover, these initiatives should fully take into account the EU legislations and the competences defined in the Treaty.



Appointment of a Member of the Executive Board of the European Central Bank


13651/2019 – C9-0173/2019 – 2019/0818(NLE)

Date of consultation / request for consent





Committee responsible

 Date announced in plenary







 Date appointed

Irene Tinagli





Discussed in committee





Date adopted





Result of final vote







Members present for the final vote

Gunnar Beck, Marek Belka, Stefan Berger, Gilles Boyer, Cristian-Silviu Buşoi, Derk Jan Eppink, Engin Eroglu, Markus Ferber, Jonás Fernández, Raffaele Fitto, Frances Fitzgerald, Luis Garicano, Valentino Grant, José Gusmão, Enikő Győri, Danuta Maria Hübner, Stasys Jakeliūnas, Othmar Karas, Billy Kelleher, Ondřej Kovařík, Philippe Lamberts, Aušra Maldeikienė, Jörg Meuthen, Csaba Molnár, Luděk Niedermayer, Dimitrios Papadimoulis, Piernicola Pedicini, Lídia Pereira, Jake Pugh, Evelyn Regner, Antonio Maria Rinaldi, Robert Rowland, Martin Schirdewan, Pedro Silva Pereira, Paul Tang, Irene Tinagli, Inese Vaidere, Johan Van Overtveldt, Stéphanie Yon-Courtin, Marco Zanni

Substitutes present for the final vote

Carmen Avram, Gabriele Bischoff, Damien Carême, Fabio Massimo Castaldo, Richard Corbett, Agnès Evren, Eugen Jurzyca, Pedro Marques, Fulvio Martusciello, Ville Niinistö, Bogdan Rzońca, Stéphane Séjourné, Monica Semedo, Antonio Tajani, Julie Ward

Substitutes under Rule 209(7) present for the final vote

Rosa D’Amato, Anna Deparnay-Grunenberg, Dino Giarrusso

Date tabled




[1] Not yet published in Official Journal.

[2] Texts adopted, P8_TA(2019)0211.

Last updated: 9 December 2019Legal notice - Privacy policy