The European Commission has held a very brief (4 week) exploratory consultation on the implementation in the EU of the revised framework resulting from the Basel 4 reviews. The BSA has responded directly to this consultation, as well as contributing to and supporting the collective response from the European Association of Co-operative Banks.
In our response, as well as addressing some important technical issues relevant to residential mortgages, we also call on the Commission to take seriously the need for proportionality in the roll-out of Basel-derived rules (designed for large, internationally active banks) to smaller institutions. In particular, we strongly advocate the "small banking box" approach developed in Germany.
Read our full response document here.