Bob Lyddon - Lyddon Consulting Services - Thames Ditton 09 July, 2018, 17:43 0 likes

I really would like to see the Competition Law advice that allows an organisation - whose membership counts competitors of one another amongst its number - to set up a Working Group outside its own designated space (which is payments clearing) and in a space which is a prime area of competition between its members (corporate liquidity management services) and which is not terribly closely connected with payments clearing.

Revelation of information about the differences between member banks' implementations of Basel III must have occurred, as the speaker says that there are major differences: he would not be able to conclude that unless there had been disclosure of information that would normally be both proprietary and confidential, and a proprietary component in the design of products for customers.

The speaker refers to the need for greater alignment between banks, presumably of their interpretations of regulation: why is such an alignment needed? Who would that benefit? How will that alignment translate into the feature and function in the range of offerings proposed to customers? Surely it will tend towards harmonisation of the feature and function if the design component "Impact of Applicable Regulation" comes up the same across all competitors.

The speaker also says that the technology impact on banks will be discussed and what the technology needs are within the banks to handle corporates' liquidity management needs in the future: technology is a prime driver of achieving competitive advantage. What is the potential benefit to customers of this being discussed between competitors?

So let's either see the Competition Law advice and make sure that there are no possible detriments to the marketplace deriving from competitors comparing notes on the in-scope matters, or if there are potential detriments, what benefits to customers will arise from this collaboration taking place that justify and outweigh the detriments.

Or else this Working Group should be shut down.

Daniel Szmukler - EBA - Paris 11 July, 2018, 16:18 0 likes

The working group activities of the Euro Banking Association are to advance the understanding of new market trends. Their objective is to deliver thought leadership for the benefit of the wider public. The working groups of the Association do not address business or commercial aspects. Their deliverables are informative on trends in the area covered. 

Bob Lyddon - Lyddon Consulting Services - Thames Ditton 11 July, 2018, 16:52 0 likes

Dear Daniel - then you will have no problem in publishing the Competition Law advice that has been taken. The aspects mentioned by Mr Richter are ingredients in a customer proposition, and so these are - prima facie - business and commercial aspects.