The attention recently placed by the ECB, and not only, on the need to free the smaller banks from the burdens deriving from the application of the innovations introduced by the legislation at European level, in practice on the application of the principle of proportionality, through Sabine Lautenschlaeger , responsible for banking supervision, can only be welcomed, given that in the past Assopopolari together with others had repeatedly reaffirmed the need for an approach that takes into account the specificities that characterize local banks, under the profile of governance, size and operations.
This issue has recently come to the fore mainly due to the position expressed by the German Finance Minister Wolfgang Schäuble who presented to the European Commission a proposal called the "Small Banking Box" also supported by the British Chancellor of the Exchequer George Osborne and aimed at protecting more and more regional banks from the costs deriving from regulatory adjustments.
While on the one hand Lautenschlaeger reiterated how such a proposal cannot be considered acceptable if it envisages two distinct regulatory frameworks, given that all banks operate in competition within the same national ambit, effectively excluding what is the approach followed in the United States where the largest banks are subject to Basel III regulation and the others, however, respond to a set of national internal rules, on the other hand it is always positive that the principle of gradualness or, in any case, the awareness of having to distinguish credit institutions between large and small is also felt by the European Central Bank.
That this topic is at the center of attention of the German authorities is also confirmed by the recent speech by the president of the Association of German Savings Banks Georg Fahrenschon who underlined how adequate regulation must take into account the business model and size, while preserving the aptitude of these institutes and carry out their lending activity in favor of small and medium-sized enterprises. An approach that would also favor the recovery of the real economy given the large incidence of SMEs in the European production system.
For some time now, Assopopolari has repeatedly stressed that a real and concrete application of the principle of proportionality within the community provisions that had to be incorporated into our legal system could not be ignored. This is even more stringent in the Italian case, where SMEs represent 80% of employees in the private sector and 70% of the added value produced.
For this reason, also taking into account the opinion expressed by the EESC (European Economic and Social Committee), which underlined how important it is to solve the problem concerning the adequate application of the principle of proportionality in the new banking regulation and by proposing stricter requirements for banks that operate globally and are more compatible for local and territorial ones, it would be appropriate for these differentiations to be concretely implemented in the methods of contribution to the Single Resolution Fund or in what is expressly provided for in the BRRD with reference to company recovery plans, promoting simplified methods for banks that have less operational complexity than large systemically important banks.
However, we need to be vigilant so as not to risk repeating what has already happened with the application of the bail-in, i.e. the introduction of an instrument that has proven to be tailor-made for the banking systems of some countries and instead is not adequate for others, at least in its full application. It is comforting news that the need to preserve local and local banks is commonly felt in all major European countries, but it will be even more positive to introduce measures that can be truly effective and useful in the various European banking systems, without penalizing some and favor others..
* Secretary General of the National Association of Popular Banks
