The ESRB also has a formal role in the CRR/CRD, among other things through opining on some national macroprudential measures. A macroprudential framework extending beyond the banking sector But the ESRB’s macroprudential mandate extends beyond the banking sector, and not every spot on the map over the financial system is as well-known and covered from a macroprudential viewpoint as the EU banks in the remit of the CRR/CRD. The financial landscape is constantly evolving and subsequently the potential sources of systemic risks. One aspect reflecting this is that the share of credit provided by other financial institutions than banks has grown over the past few years. Hence, after making the macroprudential framework for the EU banking sector operational, targeting the parts of the map where we find the non-bank financial institutions, and working on how to provide a holistic view regarding all parts of the financial system, is a natural and important next step. The ESRB recently published a strategy paper on macroprudential policy “beyond banking”, which complements the guidance already provided on the policy framework for the banking sector. That strategy paper is meant to provide a point of reference as we now move on to further enhance the macroprudential policy strategy, regulatory data and instruments for addressing risks in non-bank financial sectors. I should mention that other work related to non-bank financial institutions has also been conducted, where the recently published annual ESRB Shadow Banking Monitor will hopefully provide important insights.

While these differences are quite likely to generate different risks, the structure of the national financial system may also in itself contribute to either mitigating or further fuelling them. One size will not fit all – national flexibility is needed It is not very long since the CRR/CRD entered into force, but we have already enough practical experience to be thinking about developing it further. In my view, that should include simplifying it. We really had very limited experience of conducting macroprudential policy in practice at the time the CRR/CRD was drafted. In principle, the Commission’s starting point was to transform the Basel III minimum capital regulation into a maximum harmonization framework. And the somewhat cumbersome procedures when using some of the instruments under the CRR/CRD are probably the result of the pretty tough negotiations which took place before the current framework saw the light of day. Today, with some more experience and a fair amount of “learning by doing”, I think most would agree that national flexibility is necessary for efficient policy implementation. Furthermore, as I mentioned earlier, the circumstances under which macroprudential policy operates are not static. Therefore, in terms of the macroprudential framework it is unlikely that one size fits all, and fits at all times. Rather, the appropriate macroprudential policy set-up, naturally including the use  |7  of its instruments, will to some extent need to be tailored. The national flexibility, which is already part of the current CRR/CRD framework, is in my view key for efficient macroprudential policies.