Reflections on Euro Area Banking Supervision: Context, Transparency, Review and Culture - A Contribution to the Conversation on the SSM after Three Years

Abstract

Reflections on context, transparency, review and culture of the Single Supervisory Mechanism (SSM), the Euro Area system of prudential supervision of banks, three years after its start. The paper discusses the 'cascade' of banking regulation (from global standards through EU legislation and harmonising technical regulations of the Commission to national laws, central bank acts and guidance) and suggests five ways to strengthen the Single Rulebook in the financial sector. The paper further explores transparency in the SSM, inter alia, discussing the public availability of Memoranda of Understanding among supervisory authorities, the ECB's Banking Supervision Manual, and information on administrative and judicial review of ECB acts, suggesting minor steps forward on the latter. The paper concludes with considerations on the context of banking union, highlighting the incidence of the often forgotten cultural aspect of integration of Europe.

Keywords: European Central Bank; Judicial Review; Administrative Review; Prudential Supervision; Single Supervisory Mechanism (SSM); Emergency Liquidity Assistance (ELA); Transparency of Supervision; Memoranda of Understanding

JEL Classification: E58; G28; K41