UK Finance would like to thank the ESAs for their work during a very challenging period of regulatory reform. We fully support the main objectives of the proposal. Increasing the integration of financial markets, market integrity, and safeguarding financial stability are among the key objectives the industry should strive to achieve. Greater supervisory convergence will deliver substantial benefits including reducing market fragmentation and supporting a level playing field.

There are a number of issues arising from these proposals that need further consideration. While we acknowledge the ESAs may need to play a greater role in the supervisory process in order to achieve convergence, awarding them further powers will in certain circumstances significantly change business practices, and any unintended consequences need to be identified and addressed.