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The EESC is fully supportive of the revised directive and it finds much in the regulation which it can support. The EESC has a major concern about the applicability of the regulation to SMEs and it recommends that the more radical proposals be revised.
The EESC expresses its firm support for the structural reform of the banking system. It considers the Commission's proposal for a regulation to be a valid and effective response aimed at separating commercial banking activities from investment activities.
The EESC supports and encourages a broad agreement to boost the economy and restore trust in the financial institutions, and calls on the Commission to promote a European Social Pact for Sustainable Finance.
Nevertheless, the EESC believes that the Commission should give greater attention to investors and employees, who have hitherto received little attention in the reform.
Besides, the EESC recommends that oversight activities be carried out in close cooperation and coordination between the EBA and the national authorities, which are well-acquainted with the markets and which will play a key role in managing the new reformed European finance.
The EESC supports the Commission's proposal to expand the scope of controls and the competency of the authorities in order to conduct checks and confiscate goods, whenever there is a reasonable indication of illicit activities. The EESC recommends to improve cooperation, both between the competent authorities and between Member States and suggests that penalties should be harmonised across Member States and communicated to the Commission in a coherent way. The Committee also proposes that, in addition to gold, other "highly liquid commodities" should be included in the definition of cash from the moment the new regulation is adopted and it draws attention to the threat of further use of pre-paid cards by criminals and terrorists to covertly finance their activities.
The EESC welcomes these proposals on sovereign bond-backed securities (SBBSs), which fit into the broader context of completing the Banking Union and building a Capital Markets Union (CMU). Moreover, the proposals also have the potential to make a positive contribution to financial stability and resilience. The EESC has been strongly advocating a weakening of the link between banks and their home countries ("sovereigns") and therefore welcomes that SBBSs aim to contribute to this. The EESC considers that in conceptual terms, the idea of SBBSs is an attractive one and feels that the only way to find out whether banks will switch from bonds from their home countries to SBBSs for their investments and whether investors will be prepared to buy "junior" tranches in sufficient quantities to justify the creation of SBBSs, is to test this new financial instrument - the SBBS - on the market.