Highlevel overview of Bank of England （英格兰银行的高级概述）.pdf

High-level overview of Bank of England Response to the European Commission Call for Evidence on the EU Regulatory Framework for Financial Services, January 2016 Structure A- Rules affecting the ability of the economy to finance itself and grow Regulatory constraints - Macroprudential toolkit in CRDIV - Consideration of inclusion of macroprudential tools in Solvency II - Excessive volatility of the risk margin in Solvency II - Treatment of infrastructure investments under Solvency II - Securitisation Market liquidity - Leverage ratio in CRDIV - Pre- and post-trade transparency under MiFID II Proportionality - Proportionality in banking regulation - Impact of IFRS 9 on banks using the standardised approach B- Unnecessary regulatory burdens Reporting and disclosure obligations - Liquidity reporting under CRD IV Contractual documentation - Contractual recognition language in Article 55 of BRRD C- Interactions of individual rules, inconsistencies and gaps Links between individual rules and overall cumulative impact - Ultimate forward rate and treatment of sovereign exposures under Solvency II D- Rules giving rise to possible other unintended consequences Risk - CRDIV bonus cap - Restrictions on Maximum Distributable Amount (MDA) under CRD IV - Design of the Countercyclical Buffer in CRD IV - Protected limits under the Deposit Guarantee Schemes Directive (DGSD) Other issues - Definition of ‘financial institutions’ under Solvency II - Disclosure requirements in the Deposit Guarantee Schemes Directive (DGSD) - Supplementary supervision under the Financial Conglomerates Directive (FICOD) 1 A- RULES AFFECTING THE ABILITY OF THE ECONOMY TO FINANCE ITSELF AND GROW The regulatory framework must contain the appropriate tools and flexibility to strengthen resilience and support growth… Macroprudential toolkit in CRDIV 1. Bank