FSC members participate in the deliberations
Deliberations and decision-making: The German authorities are of the view that FSC
members participate in the deliberations primarily as official representatives of their
respective institutions, but also in a personal capacity. Such an arrangement may foster more
open and frank discussions within the FSC, but it may also lead to confusion if the members
are called upon to reach a decision (e.g. For the issuance of a warning or recommendation)
that potentially binds their institutions without providing an opportunity for prior consultation
within their respective institutions.
Decision-making by the FSC, particularly on key issues, is supposed to be based on
consensus. Member institutions strive to achieve consensus in pre-meeting preparations and
during the deliberations of the FSC. The authorities note that, while discussions in the
Committee to date have been robust, there exists a strong national culture of consensus that
facilitates decision-making. Failure to reach consensus does not mean that a majority decision
cannot be taken (recognising that the Bundesbank retains a veto with respect to key
decisions) or that the member institutions cannot act unilaterally based on their own statutory
powers. For example, the Bundesbank could issue warnings outside the FSC through the FSR
or other public communication (e.g. Speeches), while BaFin can deploy any of the
macroprudential instruments in CRD IV/CRR without waiting for an FSC recommendation.
EU Forecast
euf:ba.18.j:56/nws-01