As a global
centre the City is engaged in ongoing competition with other
non-EU financial centres. To enhance its effectiveness and
attract more international business to the EU it is necessary
to secure and maintain a risk-based, proportionate regulatory
environment. The City therefore supports the continued process
of regulatory reform at the EU level. In particular it
welcomed the Presidencies' initiative on regulatory
reform. This was designed to tackle the administrative costs
of regulation, improve competitiveness testing and impact
assessment, simplify existing regulation and strengthen the
regulatory framework. The City of London would like this
agenda to be taken forward more vigorously and advocates:
- Regulation should only be considered after a systematic market
failure analysis has been conducted. This is essential in order to
decide whether there is a “prima-facie” case for regulatory
intervention.
- Improved consultation and use of cost benefit analysis when
designing policy.
- Obligatory use of regulatory impact assessment at the earliest
stage of policy inception.
- Auditing of impact assessments in order to measure relative
implementation costs of different options, to ensure that they are
being done rigorously and to promote best practice.
- Better and more consistent implementation and, where necessary,
enforcement of existing legislation.
- Evidentiary hearings in Brussels after several years experience
of implementation across the EU to establish whether the final
policy meets the original objectives of the policy makers. We would
welcome further initiatives in this area.
- Targeted amendments of existing legislation rather than the
introduction of brand new legislation.