Skip to main content

Positions

Joint letter on the treatment of incoming third country branches - September 2021

Based on a recently released EBA report on the treatment of incoming third country branches (TCBs), the Commission will include new provisions governing third country branches in its Basel III implementing proposal which is expected for October 27.  The American Chamber of Commerce to the European Union (AmCham EU), the Bank Policy Institute (BPI), the Japanese Bankers Association (JBA), and the Swiss Finance Council (SFC) have jointly signed a letter addressed to Commissioner Mairead McGuinness and to the EBA Chairman José Manuel Campa in order to recall the economic benefit of third country branches in the EU and express their concerns in relation to subsidiarisation requirements.

At the same time the signatories point out that they understand the rationale behind the EBA’s work, in particular the desire to address divergences in regulatory and supervisory approaches across Member States. Proportionate supervisory and/or regulatory measures aimed at ensuring supervisory visibility of branch activities and risks should be pursued before exploring structural measures which could negatively impact funding for businesses and the European economy.

Download

Previous Positions

European Commission consultation on the draft EU Taxonomy Article 8 Delegated Act - June 2021

European Commission Consultation on the Renewed Sustainable Finance Strategy - July 2020

Joint letter to Vice-President Dombrovskis: “Investment Firm Regulation – third country firm regime" - November 2018

Joint letter to EU Finance Ministers in response to the proposal for an EU Digital Services Tax - November 2018

Public consultation on Fintech: a more competitive and innovative European financial sector - June 2017

Call for evidence: EU regulatory framework for financial services - January 2016

SFC response to European Commission Consultation on the impact of CRR/CRD4 on bank lending

SFC response to European Commission Consultation on EMIR Review

SFC response to European Commission Green Paper on Capital Markets Union

SFC response to IOSCO Consultation on Cross-Border Regulation