Positions

From the Advocacy Newsroom - Positions

• January 14, 2011: ECIIA speaks out in response to the consultation paper of the European Banking Authority on Internal Governance. (Read more ECIIA document Comments on EBA – CEBS consultation n. 44).
  The paper addresses important aspects of internal governance including corporate structure and organization, responsibilities and roles of the management body, risk management principles, internal control effectiveness, systems and continuity, and transparency. Among the suggestions offered by the ECIIA is the increased focus on the Three Lines of Defense framework.
  *The EBA (European Banking Authority) established by the European Parliament in November 2010, provides advice to the EU institutions in the areas of banking, payments and e-money regulation as well as on issues related to corporate governance, auditing and financial reporting. Learn more on CEBS Guidebook on Internal Governance.

• December 8, 2010: ECIIA commented on the European Commission's Green Paper “Audit Policy: Lessons from the Crisis” (see PDF attached). As an overall comment, the ECIIA believes that a debate on the role and the scope of the external auditor as a major contributor to increased financial stability should also include clarification on the role of internal auditors and more specifically their interaction with other assurance providers – including external auditors. In addition to adding value to this debate, a proper consideration of internal audit’s contribution to improved governance- and risk management structures in future regulatory initiatives will add to increased financial stability. Further detail this overall comment in relation to some of the statements in the Green Paper can be found if you click here.

• June 2, 2010: The Commission launches a debate on corporate governance in financial institutions.
  In response to the financial crisis, the Commission committed itself in its March 2009 Communication on "Driving European Recovery" to improving corporate governance in financial institutions. The Commission wanted to ensure that the interests of consumers and other stakeholders are better taken into account, businesses are managed in a more sustainable way and bankruptcy risks are reduced in the longer term.
  As a first step, the Commission is now launching a public consultation on a Green Paper that details possible ways forward to deal with the following issues:
  - How to improve the functioning and the composition of boards of financial institutions in order to enhance their supervision of senior management;
  - How to establish a risk culture at all levels of a financial institution in order to ensure that long-term interests of the business are taken into account;
  - How to enhance the involvement of shareholders, financial supervisors and external auditors in corporate governance matters;
  - How to change remuneration policies in companies in order to discourage excessive risk taking.
  ECIIA’s comments on this green paper can be found here.
• April 8, 2010: ECIIA commented on a “Call for Evidence on Cross-Sectoral Internal Governance Issues”, a joint initiative from the 3L3 committees: CESR, CEBS and CEIOPS
  In order to explore ways of promoting greater convergence of regulatory and supervisory practices in the area of internal governance, the 3L3 committees conducted a stock take on and analysis of existing internal governance requirements applicable in the areas of banking, insurance and securities. A report, containing the results of this stock take can be found here. ECIIA’s comments on this exposure draft can be found here.
• January 15, 2010: ECIIA commented on CEBS’ Consultation Paper N°30 “Disclosure Guidelines – Lessons learnt from the financial crisis”
  The draft guidelines aim to address ways of improving the form and the content of disclosures, irrespective of their context or framework. While the principles reflect the disclosure-related lessons learnt from the financial crisis, they are not exclusively aimed at crisis situations. In fact CEBS feels that the guidelines can be useful when related to activities that warrant particular attention, irrespective of the economic environment.
  ECIIA’s comments on this exposure draft can be found here.
• September 21, 2009: ECIIA commented on CESR's Consultation Paper No. 09-624; ''CESR's Technical Advice to the European Commision on the level 2 measures related to the UTICS company management passport''. CESR's consultation paper can be found here.
• June 8, 2009: ECIIA commented on CEIOPS Consultation Paper No. 33; Draft CEIOPS' Advice for ''Level 2 Implementing Measures on Solvency II: System of Governance''. CEIOPS' consultation paper can be found here.