FSC also heeds the December 2011 ESRB recommendation on the macroprudential mandate
The FSC also heeds the December 2011 ESRB recommendation on the macroprudential
mandate of national authorities. In responding to that recommendation, Germany has opted
for a board structure. The design of macroprudential oversight appears to be both pragmatic
and reflective of the pre-existing institutional arrangements.
The FSC brings together a sufficiently large number of key officials with a wide range of expertise, perspectives and
responsibilities. The organisational design attempts to strike a balance between the
responsibilities of the institutions represented in the FSC – BMF, Bundesbank, BaFin and, as
a non-voting member, the FMSA – and their respective individual mandates. The FSC is
designed to be operationally independent in order to foster effective coordination, while the
FSA acknowledges the Bundesbank’s independence as set in statute.
The FSC is already functional but, with just about a year of existence, it is too early to
evaluate effectiveness in attaining its mandated objectives. Its operational and strategic
framework – which is partly dependent on broader EU/euro area macroprudential policy
developments – has not yet been fully developed. Nevertheless, the authorities emphasise that
the FSC has already played an instrumental role in strengthening cooperation between its
members as well as deepening and formalising the information sharing arrangements between
the Bundesbank, BaFin, and the FMSA.
In that context, the main benefit of the FSC has been
to act as an overlay to the existing institutional structure (without seeking to usurp or
duplicate mandates and powers) by enhancing coordination and information exchange among
senior policymakers across different authorities.
EU Forecast
euf:ba.18.j:51/nws-01