EBF adviser: Daniele De Gennaro
Publication date: 15 November 2017
The European Banking Federation has responded to the European Commission’s consultation on post-trade in a Capital Market Union: dismantling barriers and strategy for the future. The purpose of this consultation was to learn stakeholders’ views about the current state of post-trade markets, the main trends and challenges faced by post-trade services providers and their users, and to determine the existence and scale of remaining or new barriers, the risks associated with such barriers and the best ways to address them.
Since the EBF has been heavily involved in and have contributed to develop both the main EPTF Report and the Detailed Analysis of the European Post Trade Landscape, our response focuses on the section related to EU and global trends, new technologies and competition in post-trade rather than on questions regarding the EPTF report itself.
We believe that, in order to implement the EC CMU strategy, it is imperative to work towards complete and timely dismantling of all identified barriers. This is a necessary pre-condition for full integration of EU capital markets. With the removal of the identified barriers, the post-trade services reform will significantly contribute to the global competitiveness of EU capital markets.
It is also important to note that banks are seeking to embrace and develop new technologies, solutions and business models. However, the dismantling of EPTF Barriers should not be made dependent on possible future benefits deriving from disruptive technological developments (e.g. DLT).
Furthermore, we would like to highlight the need to continue a close and institutionalised cooperation between the public and the private sector, especially through targeted dialogue amongst subject matter experts.
Finally, we would like to encourage the Commission to implement some form of coordination over the implementation process towards the dismantling of all EPTF Barriers.