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Part VI Reporting and Disclosures, 20 Applying Proportionality to the Prudential RegimeReporting and Disclosure Requirements for Smaller Banks

Christos Hadjiemmanuil

From: Capital and Liquidity Requirements for European Banks (1)

Edited By: Bart P.M. Joosen, Marco Lamandini, Tobias H. Tröger

From: Oxford Legal Research Library (http://olrl.ouplaw.com). (c) Oxford University Press, 2023. All Rights Reserved.date: 22 May 2024

Bank supervision — Prudential regulation — Basel accords — Capital requirement — Leverage — Liquidity

This chapter investigates the demand for proportionate regulation, in response to the great wave of prudential reregulation that followed the Global Financial Crisis (GFC). This has resulted, not only to a significant tightening of the prudential requirements, but also to a drastic increase in the intensity and complexity of day-to-day supervision, including supervisory reporting. For smaller banks, the challenge is daunting and could have grave competitive implications. Their predicament has turned the necessity and proportionality of the new prudential requirements into a central theme of the banking regulatory debate. The chapter then looks at the technique used by the Capital Requirements Regulation (CRR) II to relieve the members of the newly established class of ‘small and non-complex institutions’ from excessive and unjustifiable regulatory burdens — in particular, those relating to supervisory reporting requirements and public disclosure obligations. It also considers the streamlining and integration of all information-related obligations of banking institutions to reduce the complexity of the existing system, eliminating duplicative reporting by institutions, and improving the accessibility and usability of regulatory information.

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