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The response welcomed the effort for structural reform, but called for an increased stakeholder involvement in the process. As UNI has argued to Commissioner Barnier before, the non-financial services provider perspective is crucial to include. Employees and trade unions must be represented in the group in order to adequately address these key perspectives.



UNI Europa Finance commented question by question on the question of structural reform. In regards to banking reforms, UNI Europa remarks that the measures currently being implemented go in the right direction, but calls for further reform in:

1) creating a global and comprehensive regulatory system, with a high level of coordination,

2) maintaining diversity in the finance industry, including private, public and cooperative organisations of all sizes,

3) commercial and retail operations insulated from the high-risk speculative and investment banking practices.



The crucial elements to address to address the crisis are for the short-term to stabilise the finance industry and make financial markets work properly again, and in the long-term outline and undertake systemic reform. This reform must take into consideration both the role of the financial sector in the real economy and taking into account labour and social factors. The comments attached further break down the elements needed to ensure these are addressed.



In regards to the structural reform efforts proposed to date (such as the Volcker Rule and ICB proposal), UNI Europa Finance “supports the principle which is reflected in both approaches: Savers’ money must never be used for speculative and high risk operations.” UNI adds, however, that the role of bank sector employees in the implementation of these reforms must be reflected in the reforms from the very start.



UNI Europa Finance recommends banks include the following elements in their restructuring process:

1) efficient risk assessment and management,

2) whistle blowing as a tool for risk assessment and direct access for supervisory authorities,

3) employee representation in companies’ boards as a corrective measure in corporate governance.



In regards to the questions presented to corporate customers, UNI Europa Finance expressed concerned that they ask the services and products sought by corporate customers, while disregarding the retail, while in another question implies that the move away from prudential banking is an unquestioned trend, with regulation as “constraints” upon it.



In response to the questions posed to retail customers, UNI’s response highlighted the need to ensure that banks take into account society at large and the real economy, by reducing the pressure to increase consumer costs while maintaining high levels of remuneration in some areas. Moreover, in order for customers to receive good and fair advice, employees must have the right to give it by eliminating the sales pressure from management.