François Villeroy de Galhau: The Banking Union ─ Time to move
forward again
Speech by Mr François Villeroy de Galhau, Governor of the Banque de France, at the Eurofi
Financial Forum, Ljubljana, 10 September 2021.
* * *
I would have liked to be in Ljubljana today, but I extend my warmest thanks online to David Wright
and Didier Cahen for making this event possible. During the acute phase of the crisis, EU
governments and the ECB did the right thing in supporting economies, so that we can now
bounce back quickly. The European banking system proved its resilience, and contrary to many
exaggerated fears, there will be no tsunami of corporate insolvencies, and hence no major rise in
NPLs. However, now that firefighters have been successful, it is time to turn to our architects to
start building again: Europe must finally unlock the full potential of its Banking Union. This
morning I will be in the same vein as Andrea Enria's impressive speech yesterday, which I fully
welcome and support. Today, I will first discuss where we stand including the ongoing deadlock
in the Banking Union, before elaborating on the pragmatic solutions we can come up with.
I. Banking Union: it is time to move forward again
Where we stand. After a strong initial impulse having achieved an efficient first pillar -
supervision -, Banking Union now lacks momentum and remains incomplete. Let us be frank:
the project has come to a complete standstill. While the initial ambition was to create a unified
area where European banks could operate efficiently, we are still struggling with intra-European
borders. The European banking sector remains far too fragmented. In 2019, the market share of
the top five US banks was 43% [of domestic consolidated assets], compared with only 23% for
the top five in Europe. There are still too many roadblocks to cross-border restructuring:
geographical ring-fencing practices prevent groups from managing liquidity and capital efficiently
on a consolidated basis. As a result, fewer than ten cross-border M&A deals have been signed
since 2014, compared with 180 domestic deals over the same period, a historic low: at present,
Banking Union has meant that our banks are actually not more Pan-European. This paradox is
intolerable.
The creation of the Banking Union itself was a direct response to the
Why it remains crucial.
sovereign debt crisis in Europe and its impact on the bank-sovereign nexus in a context of
fragmented supervision. Beyond the need to mitigate any future crisis, the achievement of the
Banking Union remains of the utmost importance, for both micro and macro reasons.
At the micro level, moving further towards a true single banking market through cross-border
restructuring is a matter of strategic autonomy. Genuine Pan-European banking groups could
operate more effectively, raise their profitability thanks to scale effects and better face up to
foreign competition, especially from the United States. Europe is clearly losing momentum and
competitiveness here: the market share of the six major US investment banks in Europe towards
their six major European competitors has increased from 44% to 58% in the last seven years.
Moreover, larger groups could invest more in the key challenge of digital transformation: as most
of the investment costs are fixed, size is a decisive advantage. But not only the largest, all other
institutions will benefit from the increased depth of the market, allowing to reap the fruits of their
competitive advantages in a larger market.
At the level - and I say this as a central banker -, Banking Union would decisively
macro
enhance private risk sharing within Europe. The political discussion and energy remain primarily
focused on public stabilisation mechanisms, such as a possible common fiscal capacity. Let
me stress that private stabilisers are just as important and efficient, and less divisive. Banking
Union would enable, in conjunction with progress towards a Capital Market Union, a better
channelling of our abundant savings through a genuine "Financing Union for Investment and
Innovation".
How to move forward again. The first obvious fact is that we should neither relax now that the
banking crisis is mostly over, nor wait for the next crisis to act. It is precisely because we are not
in a crisis situation that we should move forward now. First, we have spent too much time and
energy on protracted discussions on prerequisites and pre-conditions, such as a full EDIS, itself
pre-conditioned by sovereign de-risking. Second, we should not focus on the creation of new
instruments and their financing, but start by making existing ones work better. Third, in order to
move beyond political divisions, we need to abandon the sequential approach in which the issues
are discussed one after another, so that the smallest obstacle can bring the whole process
grinding to a halt. I would like to call for simultaneous, parallel movements on several fronts
While welcoming the ambition of the
and to broaden the scope of possible action.
Eurogroup's "package" and its President, such a pragmatic method of small and parallel steps
could help to move forward again. None of these steps is sufficient, but each of them taken
separately would be welcome. Or if you prefer a restaurant analogy, call this proposal "à la carte"
rather than a "set menu"... bearing in mind that at the end our lunch must be just as substantial
and significant.
II. Four pathways towards reigniting the Banking Union
Building on this approach, I would like to share with you four possible and broader pathways
towards a stronger Banking Union.
1. Moving beyond home/host issues. On this topic, I would like to start by issuing a wake-up
call on the effective implementation of cross-border liquidity waivers within the union, as
prescribed by the European legislation. They remain far too limited in practice. The discussions
on the completion of the Banking Union are already at a standstill; we need, at least, to fully
harness the existing measures! Supervisors must allow the effective implementation of liquidity
waivers provided for in the level 1 text. In this regard, the fact that the SSM published guidance
mentions the need, in a first phase, to comply with 75% of the liquidity requirements at the
individual level in order to grant a cross-border waiver creates an additional obstacle. And we
shall not give up on the extension of intra-group waivers to MREL and capital requirements. Let
me add three possible ways of making progress: we could first think of a system of workable
guarantees between the parent company and its subsidiaries. Backed by the common
supervisor, they should provide enough reassurance to host countries, so that they could support
waivers in local subsidiaries.
Another step would be to ensure preferential treatment for intragroup exposures within the
Banking Union. There should be no cases where there is a difference between the treatment of
domestic and cross-border intra-group exposures, be it for liquidity or capital requirements.
To go further, in parallel with the aforementioned options, we also need to explore the possibility
of relying more extensively on the branchification of subsidiaries located in other Banking Union
countries. This was the core of Andrea Enria's statement yesterday. The branch would then
abide fully by the home country's prudential rules. The example of Nordea demonstrates the
feasibility of such an option. I am well aware that it raises substantial questions, for banks
themselves - for their governance, their brands, their relationships with customers - as well as
for deposit guarantee schemes. On this latter issue, the current legislative framework needs to
be revised in order to remove the strict limitations on the transfer of past contributions to the new
DGS in the case of a branchification. These questions are all the more reasons to seriously
investigate this option with the banking industry, as soon as possible.
2. Finding alternatives to EDIS. On the "third pillar" of the Banking Union, we must
acknowledge the intractable oppositions to a fully-fledged EDIS, and adopt a more realistic
approach. By changing the name and the content, perhaps we could regain momentum and
willingness to make progress together. We could call it the "Common deposit mechanism". It
would combine a well-known idea with a new one: (i) the well-known idea of a liquidity support
system between national DGSs, - and obviously ensuring that each of them is funded as
expected - combined with (ii) a renewed approach, in which foreign subsidiaries would be
affiliated to the home DGS. The first leg of this new tool would already provide increased funding
possibilities. The second leg would provide a serious safeguard to host countries, as they would
not bear the cost in the event of an idiosyncratic crisis.
3. Completing the resolution framework. The third pillar - deposits - has been excessively
polarising discussions for years. The "second pillar" is seen as more technical while it is at least
as important. It currently leaves unaddressed several issues relating to the European banking
sector, namely non-viable banks and overcapacities. In this respect, the targeted review of the
crisis management framework, which is being carried out by the Commission, should aim at
ensuring that the resolution mechanism is more consistent and applies to a larger scope of
banks - including small and medium. This does not mean that all banks should be preserved by
resolution but that the tools of resolution should also be usable to favor the exit from the market
of unviable banks. There is no need to further increase the size of the Single Resolution Fund for
this, as we have introduced a backstop by the ESM.
But we shouldn't forget about another subject: how to ensure the provision of liquidity in
resolution. Indeed, even if a resolution successfully restores a bank's solvency, the bank may not
be able to obtain sufficient market liquidity while it is in resolution. In the case of a systemic bank,
the amounts needed could be very significant. A "Eurosystem Resolution Liquidity" could be
provided by the ECB at this end as discussed in 2018. This raises the issue of the guarantee
framework that should support this facility in order to comply with the European legal framework.
Another difficult but meaningful way forward for the resolution framework is the harmonisation of
bank bankruptcy regimes across Europe. I am conscious that bankruptcy regimes, often
mentioned in the framework of the CMU, represent a legal challenge. Let us see how we could at
least progress on this issue for bank bankruptcies. This work may be focused on the more
essential points to facilitate consistency with the resolution tools, like treatment of
depositors/creditors hierarchy.
Finally, looking forward now, let me
4. The need for an integrated approach to new players.
consider broader developments in the financial sphere. Recent trends in financial innovation have
fuelled the emergence of a renewed financial intermediation ecosystem, involving new players -
including tech companies, be they FinTechs or BigTechs. The associated technological
disruptions have resulted in regulatory arbitrage practices, especially on the banking market.
Lending activities by non-bank financial intermediaries also circumvent prudential regulation. I
wish to stress a major point here: we must avoid repeating the mistakes of the past. Innovation
must not translate into further fragmentation. Right from the start we should try to have an
integrated supervision at the European level for new players and new technologies.
Regarding innovation, private initiatives do have their role to play in fostering a European
integration. Here, let me commend the European Payments Initiative (EPI) project. The EPI will
provide citizens with a unified, innovative and autonomous European payment solution, as an
alternative to the dominant and extra-European players already established in Europe or the
BigTechs in the future. We must support the emergence of such Pan-European projects, in
order to preserve and reinforce our financial sovereignty. And we don't have much time to
succeed, in the very next years.
***
In conclusion, let me come back to the natural complement to the Banking Union: the Capital
Markets Union. We all agree that we badly need it, even more so after Brexit: here in Eurofi, on
the Governing Council, and - in principle - around the Ecofin table. But almost nothing, or very
little, has been done. One paramount reason for this failure is that our technical product has not
so far engaged sufficient political ownership. We need a stronger purpose, a more visible "flag".
Let me suggest one: the implementation of the European Green Deal will require the reallocation
of resources towards "green" activities, in a Financing Union for Sustainable Investment. To keep
its leadership in the green transformation, Europe must act as a united block in its financing.
Moving forward on the Banking Union requires effort, but the rewards will make it more than
worthwhile. Thank you for your attention.