criteria for assessing the suitability of candidates are implemented and interpreted differently across the various euro area countries. another source of regulatory fragmentation is the supervisory powers under national law that are not explicitly mentioned in crd iv. this concerns, for instance, major transactions which can be very relevant for the risk profile of a bank : for example, a bank acquiring a non - bank, or mergers and de - mergers involving a bank or transfers of assets. in some member states, these transactions need to be approved by the competent authority ( and rightly so ), in others they do not. and such regulatory fragmentation is not just a legacy we inherited from former times. even today, there are cases where fragmentation is actually being increased. in some countries, national legislators are converting non - binding supervisory practices into binding legal acts, thereby making it harder for the ecb to harmonise these practices. a recent example is the german law on bank resolution. this law delegates to the ministry of finance the power to issue regulations in areas such as internal governance and risk management. consequences of an imbalance between supervisory and regulatory harmonisation the regulatory landscape in europe is still fragmented. and from my point of view, many variations in national legislation can no longer be justified now that we have european banking supervision. imagine being a referee in a football match ; your main task is to administer the rules of the game. but what if the individual players adhere to different rules? in such a game, you as the referee would be forced to apply different rules depending on the player in question. you would have to judge similar situations in a dissimilar way – a foul by one player might warrant a penalty kick ; a foul by another player might not. in a sense, the ssm is that referee. article 1 of the ssm regulation requires the ecb to carry out prudential supervision “ with full regard and duty of care for the unity and integrity of the internal market ”. the article also refers to the “ equal treatment of credit institutions with a view to preventing regulatory arbitrage ”. a fragmented regulatory framework makes it difficult for the ecb to meet these requirements. in extreme cases, we are faced with 19 different legislations. and in many cases, we indeed have to judge similar situations in a dissimilar way. taking decisions under such bis central bankers ’ speeches circumstances is complicated and time - consuming. it requires substantial resources and is at odds with the idea of having a single european supervisor and a

of the french senate, 14 may, page 3. cf. “ 3rd islamic financial services forum : the european challenge ”, jointly organised with the financial stability institute and hosted by banque de france on islamic liquidity management, paris, 3 march 2009. robin wigglesworth ( 2009 ), “ islamic bonds spark rush of international interest “, financial times, 10 november ; “ has the crisis shown the strengths or the weaknesses of islamic finance? ”, global market monitor, 21 october. norbert hellmann ( 2009 ), “ finanzkrise taucht islamic banking in ein neues licht ”, frankfurt borsen - zeitung, 10 november. durmus yilmaz ( 2009 ), “ islamic finance : during and after the global financial crisis ”, istanbul, 5 october. practically demonstrates the positive diversification effect they could play, contributing therewith to a systemic equilibrium. moreover, islamic finance acts as a natural hedging scheme restricting excessive credit boom in so far as it links the supply of financing ( what would conventional banks call credit ) to the growth rate of the economic activity. thank you very much.