U.S. Chamber Comment Letter to the European Commission on Non-Bank Financial Intermediation

The U.S. Chamber of Commerce (“Chamber”) appreciates the opportunity to comment on the European Commission’s (“Commission”) Consultation on Assessing the Adequacy of Macroprudential Policies for Non-Bank Financial Intermediation (“Consultation”), which aims to collect input from various stakeholders to support: (i) evaluating the effectiveness of existing macroprudential tools; (ii) reviewing the adequacy of existing microprudential and reporting tools; and (iii) assessing the possibility of introducing new macroprudential tools.

The U.S. Chamber of Commerce[1] is the world’s largest business organization. Our members range from small businesses and local chambers of commerce, to leading industry associations and global corporations, to emerging and fast-growing industries driving innovation and progress. Our members represent the various sectors highlighted in this Consultation, many of which are either headquartered in or operate in Europe.

The Chamber has been a leading voice and an active participant in debates surrounding systemic risk and regulatory supervision, and the importance of ensuring the financial stability of our capital markets. For over a decade, the Chamber has strongly supported an activities-based approach to addressing risks to non-bank financial stability in our engagement with the Financial Stability Oversight Council (“FSOC”), Financial Stability Board (“FSB’), International Organization of Securities Commissions (“IOSCO”), and the European Union (“EU”) when it first launched the Capital Markets Union. Our thoughtful approach included a 2013 report to the FSOC and U.S. prudential regulators with policy ideas to encourage transparency, due process, and data-driven approaches to financial stability oversight.[2] Applying entities-based policies or bank-like regulation to non-banks could make the financial system less competitive and more vulnerable to economic shocks.

We offer the following comments as the Commission assesses Non-Bank Financial Intermediation policies within the EU.

Click here to view the letter.

[1] Chamber of Commerce of the United States of America, European Union Transparency Registration Number 483024821178-51.

[2] See Financial Stability Oversight Council Reform Agenda found at https://www.uschamber.com/assets/archived/images/documents/files/2013_financial-stability-oversight-council-reform-agenda.pdf.