Erhvervs-, Vækst- og Eksportudvalget 2017-18
ERU Alm.del Bilag 89
Offentligt
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Why it matters to consumers
Consumers need to be able to trust that the financial products that they are being offered
are safe and fair. They expect that supervisory authorities exist to monitor the financial
institutions and to intervene when the latter do not comply with legislation. However, many
national financial supervisors lack a clear statutory objective to provide consumer
protection or do not possess sufficient resources and the capacity to perform this task. As
a result, significant consumer detriment occurs in the area of retail banking, payments,
investments, insurances, and savings. The review of the European Supervisory Authorities
is a good opportunity to harmonise the quality of supervision and enforcement everywhere
in the EU to better protect users of financial services.
Summary
Consumers expect financial products on the market to respond to their needs and to meet
legal standards. Financial supervisors must therefore deal with consumer protection
effectively and independently. Over the past few years, several EU laws have been adopted
in retail financial services. The current challenge is to ensure that this legislation is properly
implemented and enforced at the national level. However, in many Member States, the
quality of supervision is poor.
There is an urgent need to upgrade the quality of supervision and enforcement everywhere
in the EU to achieve supervisory convergence. BEUC proposes to create an EU supervisory
authority dedicated only to consumer issues, as the consumer protection mandates of the
existing ESAs has been treated as a marginal issue so far. The main task of the ESAs is
financial stability which has no direct link with consumer protection, as market conduct
supervision is very different from prudential supervision by nature.
BEUC proposals for the reform of the European Supervisory Authorities are as follows:
•
•
Set up a separate EU supervisor that would focus on defending consumer interests
in financial services (twin-peak model of supervision).
Provide a mandate to the EU consumer protection supervisor to achieve supervisory
convergence, i.e. ensure the development, implementation and monitoring of
minimum standards of conduct-of-business supervision at Member State level. This
entails having financial supervisors with strong consumer protection mandates,
sufficient resources, and the power to fulfil their mandates in all Member States.
Grant the EU consumer protection supervisor direct supervisory and effective
product intervention powers with regard to cross-border issues, as well as EU-wide
negative trends and risky products/practices that are widespread across several
Member States.
Reform of the ESAs’ governance (Management Board and Board of Supervisors)
aimed at improving their operational efficiency and ensuring supranational
orientation of their work.
Provide the ESAs with sufficient resources to adequately fulfil their tasks.
Enhance the functioning of the ESAs’ stakeholder groups.
•
•
•
•
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General comment
BEUC welcomes
the opportunity to respond to the Commission’s
consultation
on the
operation of the European Supervisory Authorities (EBA, ESMA and EIOPA). The ESAs
review is an excellent opportunity to bring real changes for EU consumers in retail financial
services and demonstrate the EU institutions’ commitment to putting consumer
protection
at the heart of their policy-making, in particular as far as enforcement of the EU law is
concerned.
Overall, we agree with most of
the Commission’s analysis
on the ESAs’ activities and the
shortcomings identified. It is worth stressing that all those shortcomings (such as a weak
mandate for consumer protection, problems linked to the ESAs governance, funding issue,
etc.) were already recognised by the Commission in its 2014 ESAs evaluation report (3
years ago).
1
In this response, BEUC puts forward a number of concrete suggestions to
improve the efficiency of market conduct supervision and consumer protection at national
and EU level. We strongly encourage EU policy-makers to step up their efforts in integrating
financial consumer protection across the EU.
I.
Tasks and powers of the ESAs
Supervisory convergence
Question 1.
In general, how do you assess the work carried out by the ESAs so far in
promoting a common supervisory culture and fostering supervisory convergence, and how
could any weaknesses be addressed? Please elaborate on your response and provide
examples.
Question 2.
With respect to each of the following tools and powers at the disposal of the
ESAs:
•
peer reviews (Article 30 of the ESA Regulations);
•
binding mediation and more broadly the settlement of disagreements between
competent authorities in cross-border situations or cross-sectorial situations
(Articles 19 and 20 of the ESA Regulations);
•
supervisory colleges (Article 21 of the ESA
Regulations); To what extent:
a)
have these tools and powers been effective for the ESAs to foster
supervisory convergence and supervisory cooperation across borders and
achieve the objective of having a level playing field in the area of
supervision;
b)
to what extent has a potential lack of an EU interest orientation in the
decision making process in the Boards of Supervisors impacted on the
ESAs use of these tools and powers?
Please elaborate on questions (a) and (b) and, importantly, explain how any
weaknesses could be addressed.
Question 3.
To what extent should other tools be available to the ESAs to assess
independently supervisory practices with the aim to ensure consistent application of EU
law as well as ensuring converging supervisory practices? Please elaborate on your
response and provide examples.
1
http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:52014SC0261
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Question 4.
How do you assess the involvement of the ESAs in cross-border cases? To
what extent are the current tools sufficient to deal with these cases? Please elaborate on
your response and provide examples.
BEUC response
See our response to questions 6 & 7 with regard to supervisory convergence in market
conduct supervision.
Non-binding measures: guidelines and recommendations
Question 5.
To what extent are the ESAs tasks and powers in relation to guidelines and
recommendations sufficiently well formulated to ensure their proper application? If there
are weaknesses, how could those be addressed? Please elaborate and provide examples.
BEUC response
The Commission’s 2014 report states that the ESAs’
guidelines and recommendations
contribute to the establishment of high-quality common regulatory and supervisory
standards and practices and ensure the common, uniform and consistent application of
Union law. At the same time, the Commission recognises that uncertainties remain with
regard to the nature and scope of the guidelines and recommendations.
2
Indeed, the non-binding nature of the recommendations, guidelines and opinions issued
by the ESAs with regards to consumer and investor protection seriously undermines their
effectiveness. Many national supervisory authorities do not even have a consumer
protection objective and mandate
3
or have a limited mandate. They can choose to ignore
important standards, guidelines, and recommendations. The guidelines and
recommendations are useful because, due to their level of details and accuracy, they limit
the risk of divergent interpretations between supervisors on the one hand, and supervised
firms on the other hand. As a result, BEUC considers that current guidelines and
recommendations should take the legal form of binding instruments to ensure convergence
of regulatory, supervisory and enforcement practices, so that appropriate measures are
taken on the national level to protect the consumer interest (see our response to questions
6 & 7 regarding supervisory convergence).
Consumer and investor protection
Question 6.
What is your assessment of the current tasks and powers relating to
consumer and investor protection provided for in the ESA Regulations and the role played
by the ESAs and their Joint Committee in the area of consumer and investor protection?
If you have identified shortcomings, please specify with concrete examples how they could
be addressed.
Question 7.
What are the possible fields of activity, not yet dealt with by ESAs, in which
the ESA's involvement could be beneficial for consumer protection? If you identify specific
areas, please list them and provide examples.
2
3
Commission Staff Working Document on the operation of the ESAs and the ESFS, 2014:
http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:52014SC0261
See Annex 2 of the FSUG paper “For better supervision and enforcement in retail finance, Oct 2016:
file:///C:/Users/fal/Downloads/1610-supervision-enforcement-retail-finance_en_0.pdf
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BEUC response
The ESAs have the objective of protecting the public interest, inter alia, by enhancing
customer protection
–
this task comes last in the lists of the ESAs’
objectives
4
. A more
detailed look at the tasks related to consumer and investor protection (Art 9 of the ESAs
Regulations) shows that their consumer protection mandate is very limited, despite the
changes introduced by Regulation1022/2013.
5
In terms of concrete supervisory actions the
ESAs may, under certain conditions, prohibit dangerous financial products or activities. For
this power to be effective, delegation through sector-specific regulations and directives is
required. In that respect, the revised MiFID recently granted ESMA with product
intervention powers.
The ESAs’
regulatory
powers have been substantially extended in recent years due to the
mandates granted by sectoral financial regulations and directives. The ESAs are in charge
of drafting and advising the Commission on level 2 implementing rules (Regulatory and
Implementing Technical Standards). However, the contribution of these
supervisory
authorities to enhancing consumer protection in practice has been very limited so far. This
is a widely acknowledged shortcoming, as also documented in the Commission’s
consultation document. The ESAs’ representatives have on various occasions
stressed their
willingness to work more on consumer protection issues, and they welcomed the present
consultation as an opportunity to
further progress towards supervisory convergence and
to enhance consumer protection.
6
Today, the bulk of retail finance legislation across Europe originates from the EU level, e.g.
the Payment Accounts Directive, Insurance Distribution Directive, Payment Services
Directive, Markets in Financial Instruments Directive, Regulation on Packaged Retail and
Insurance-Based Investment Products, Mortgage Credit Directive, Consumer Credit
Directive, Deposit Guarantee Schemes Directive to name just a few. However, Member
States have some leeway on how to implement these rules, and full discretion on how to
enforce them at national level. Sectoral EU regulations and directives merely ask that
Member States designate a competent authority responsible for implementation and
oversight, and for it to apply dissuasive sanctions in case of law infringement.
The reality is that market conduct supervision of consumer issues is fragmented across
Member States which are at different levels of development with regard to consumer
protection. In 2011, BEUC commissioned a study to assess existing consumer protection
levels through the law and the practice of financial supervision which revealed that in some
Member States no authority is really in charge of consumer protection in the financial
services area. Many national supervisors lacked a clear statutory objective to provide
consumer protection; many of them were under-staffed, have little on-site inspection
capacity, had limited legal powers to make binding decisions and limited powers of
sanction; some of them did not have capacity to deal with consumer complaints.
7
All of
these problems are quite common across the EU, but they are most prevalent in central,
eastern and southern Member States.
Not only is the situation across the EU in terms of consumer protection by financial
supervisors fragmented, it also, and more fundamentally, bears serious shortcomings in
terms of enforcement of retail finance legislation. These shortcomings are documented by
the Commission’s report on the implementation of the Consumer Credit Directive in 2014.
8
4
5
6
7
8
Article 1 of the Regulations establishing the ESAs
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:287:0005:0014:EN:PDF
https://www.esma.europa.eu/press-news/esma-news/esas-welcome-european-commission%E2%80%99s-
public-consultation-their-operation
Financial supervision in the EU: A consumer perspective, BEUC study, February 2011:
http://www.beuc.eu/publications/2011-00396-01-e.pdf
EC report on the implementation of the Consumer Credit Directive, May 2014:
http://ec.europa.eu/transparency/regdoc/rep/1/2014/EN/1-2014-259-EN-F1-1.Pdf
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A recent peer review by the European Securities and Markets Authority (ESMA) on the poor
enforcement of suitability requirements under MiFID is a reminder of this problem.
9
A
recent FSUG paper also provided examples demonstrating the lack of enforcement at
national level.
10
BEUC members also regularly report mis-selling cases in retail finance as
well as the resulting consumer detriment related to retail banking, payments, investments,
insurances, and savings. As a consequence, the low level of trust that consumers have in
financial services providers and intermediaries is hardly surprising.
11
The quality of enforcement of EU law in the field of retail finance is a considerable problem
both for consumer trust and market integration. Effective enforcement and an equally high
level of consumer protection and redress everywhere across Europe are preconditions for
a successful single retail financial market and Capital Markets Union.
12
Each Member State
should have its own financial conduct authority in order to ensure that consumer protection
legislation is properly enforced everywhere in the EU. See BEUC recommendations on the
tasks and powers that all national financial conduct supervisors should have.
13
There is an urgent need to upgrade the quality of supervision and enforcement everywhere
in the EU to achieve supervisory convergence. EU institutions and stakeholders
acknowledge this. For example, developing a common European supervisory culture and
EU level convergence on conduct-of-business
supervision are among EIOPA’s top
priorities.
In that context, EIOPA has developed a strategic approach to preventive and risk-based
conduct-of-business supervision, where it intends to use various tools such as annual
consumer trends reports and peer-reviews of supervisory authorities.
14
As has been successfully implemented in several Member States following the financial
crisis (Belgium, UK) and also before the crisis (e.g. the Netherlands), BEUC has been
pushing for a twin peak model of supervision i.e. separating market conduct from
prudential supervision. We are of the view that supervisory convergence in market conduct
supervision would be better achieved by establishing an EU authority for financial consumer
protection. We appreciate the work carried out by the ESAs and actively contribute to their
work.
15
However, the ESAs deal with both prudential and market conduct supervision,
where the main priority and resources are allocated to the prudential oversight
(ESAs’
consumer protection divisions have very limited human resources), and, even worse,
where consumer protection may be subordinated to prudential objectives. The objective
of the authorities is the “short, medium and long term stability and effectiveness of the
financial system” Consumer issues in this perspective are only a
marginal issue.
Therefore, we see the need to set up a separate EU supervisor that would focus on
defending consumer interests in financial services. One of the main tasks of the new
authority should be to achieve supervisory convergence and include ensuring the
development, implementation and monitoring of minimum standards of conduct-of-
business supervision at Member State level.
9
10
11
12
13
14
15
MiFID suitability requirements, Peer review report, ESMA, April 2016:
https://www.esma.europa.eu/press-news/esma-news/esma-finds-room-improvement-in-national-
supervision-investment-advice-retail
“For better supervision and enforcement in retail finance”, FSUG, October 2016:
http://ec.europa.eu/finance/finservices-retail/docs/fsug/papers/1610-supervision-enforcement-retail-
finance_en.pdf
EU Consumer Scoreboards
See BEUC response to the Green Paper consultation, March 2016:
http://www.beuc.eu/publications/beuc-x-2016-027_fal_beuc_position_green_paper_financial_services.pdf
Need for independent and efficient national supervisors everywhere in Europe, BEUC requests, October 2011:
http://www.beuc.eu/publications/2011-09879-01-e.pdf
EIOPA’s approach to conduct-of-business
supervision:
https://eiopa.europa.eu/consumer-protection/consumer-lounge/eiopa-approach-conduct-of-business-
supervision
BEUC is represented in the stakeholder groups of all three ESAs, and we respond to all relevant consultations.
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The existing tools available to the ESAs for improving the supervisory and enforcement
practice on the national level, such as recommendations, guidelines and peer reviews are
insufficient and have in fact
no effective binding power (the ‘comply or explain’
mechanism). A serious limitation which negatively affects the efficiency of the ESAs peer
reviews is that the results of the evaluation process may be disclosed publicly only with
the agreement of the competent authority that is the subject of the peer review.
16
The new EU consumer protection supervisor should be empowered to monitor the quality
of the national supervisory practices by, inter alia, running random mystery shopping
exercises and publishing their results. The new supervisor should have sanctioning powers
in case the national competent authorities do not implement the measures recommended
by the EU supervisor aimed at improving the quality of market conduct supervision.
The new EU supervisor should also be mandated with monitoring and assessing the way
national markets function and any cross-market trends. It should also try to prevent risky
developments and consumer detriment in order to gain more intelligence and
understanding on problematic issues for consumers in the markets, e.g. by measuring
detriment and detecting mis-selling behaviour. The monitoring should be followed by an
analysis of the root causes that lead to the detrimental results for consumers. On this
basis, appropriate measures for mitigation of the detriment should be proposed.
While responsibility for day-to-day supervision of financial institutions should essentially
remain with national competent authorities (provided that their supervisory practices are
harmonized as explained above), the EU consumer protection supervisor should be granted
direct supervisory and effective product intervention powers with regard to cross-border
issues, as well as EU-wide negative trends and risky products/practices that are widespread
across several Member States. This would help take a pro-active approach to prevent mass
consumer detriment caused by toxic financial products and practices, e.g. in retail
investments or credit area
17
. Consumer treatment across Member States with regards to
the same types of detriment should be similar.
The EU supervisor should publish a performance report on an annual basis setting out how
well relevant financial markets have performed over the year and a forward looking risk
outlook setting out the key risks to the relevant consumer and market outcomes.
Enforcement powers
–
breach of EU law investigations
Question 8.
Is there a need to adjust the tasks and powers of the ESAs in order to
facilitate their actions as regards breach of Union law by individual entities? For example,
changes to the governance structure? Please elaborate and provide specific examples.
BEUC response
See our response to questions 6 & 7.
The ESAs Boards of Supervisors are composed by the 28 heads of the national competent
authorities for the supervision of financial institutions in each Member States. These
supervisors have many other priorities that the consumer dimension (see our response to
questions 22-25).
16
17
SMSG contribution to the ESFS consultation, July 2013:
https://www.esma.europa.eu/sites/default/files/library/2015/11/2013-smsg-
013_smsg_contribution_to_the_esfs_review.pdf
We believe a coordinated EU approach could help prevent massive consumer detriment of the kind that was
caused by foreign currency loans in several central, eastern and southern EU countries.
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Direct supervisory powers in certain segments of capital markets
Question 19.
In what areas of financial services should an extension of ESMA's direct
supervisory powers be considered in order to reap the full benefits of a CMU?
Question 20.
For each of the areas referred to in response to the previous question,
what are the possible advantages and disadvantages?
Question 21.
For each of the areas referred to in response to question 19, to what
extent would you suggest an extension to all entities or instruments in a sector or only
to certain types or categories?
Please elaborate on your responses to questions 19 to 21 providing specific examples.
BEUC response
Please see our response to questions 6-7 regarding direct supervisory powers.
II.
Governance of the ESAs
Question 22.
To what extent do you consider that the current governance set-up in
terms of composition of the Board of Supervisors and the Management Board, and the
role of the Chairperson have allowed the ESAs to effectively fulfil their mandates? If you
have identified shortcomings in specific areas please elaborate and specify how these
could be mitigated.
Question 23.
To what extent do you think the current tasks and powers of the
Management Board are appropriate and sufficient? What improvements could be made to
ensure that the ESAs operate more effectively? Please elaborate.
Question 24.
To what extent would the introduction of permanent members to the ESAs'
Boards further improve the work of the Boards? What would be the advantages or
disadvantages of introducing such a change to the current governance set-up? Please
elaborate.
Question 25.
To what extent do you think would there be merit in strengthening the role
and mandate of the Chairperson? Please explain in what areas and how the role of the
Chairperson would have to evolve to enable them to work more effectively? For example,
should the Chairperson be delegated powers to make certain decisions without having
them subsequently approved by the Board of Supervisors in the context of work carried
out in the ESAs Joint Committee? Or should the nomination procedure change? What
would be the advantages or disadvantages? Please elaborate.
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BEUC response
BEUC concurs with the Commission’s analysis that the governance structure of
the ESAs
can cause conflicts of interest and reduce the efficiency of their work, as described in the
consultation paper. As pointed out in BEUC response to the 2013 Commission
consultation
18
, the current composition of the ESAs Boards of Supervisors (BoS) produces
a situation where not all national authorities that are in charge of consumer protection in
financial services are represented on the BoS. This makes it difficult for consumer
protection issues to get as much attention as other issues that directly come under the
responsibility of all members of the BoS.
This is because in each Member State consumer protection is organised differently, i.e. it
falls under the competence of different bodies. This negatively impacts the decision-
making process. This shortcoming was also recognized by the Commission in its 2014
report on the operation of the ESAs.
19
We support the EC proposal for the reform of the ESAs governance (Management Board
and Board of Supervisors) aimed at improving their operational efficiency and ensuring
supranational orientation of their work. In parallel, the key issue for us is the ESAs’ role
in financial consumer protection. For it to be effective, it’s crucial
to address the conflict
between prudential and market conduct supervision through separating these two
functions. Therefore, we advocate for setting up a separate EU supervisor for market
conduct and consumer protection (see our response to questions 6 & 7).
Moreover, while the ESAs are both in charge of financial supervision and of regulation
(level 2 legislation), it is surprising that the boards are composed solely of national
supervisors. One wonders whether it is good governance that those who draft the rules
are the same the ones that are in charge of controlling its application by the firms.
Question 26.
To what extent are the provisions in the ESA Regulations appropriate for
stakeholder groups to be effective? How could the current practices and provisions be
improved to address any weaknesses? Please elaborate and provide concrete examples.
BEUC response
BEUC and several of our members are represented in the ESAs Stakeholder Groups (SG),
and we actively contribute to their work. Here is our assessment of the SGs.
Positive aspects
There is a constructive working relationship between the ESAs (chair, secretariat and
officers) and the SGs.
18
19
Review of the European System of Financial Supervision, BEUC response to EC consultation, August 2013:
http://www.beuc.eu/publications/2013-00558-01-e.pdf
Commission Staff Working Document on the operation of the ESAs and the ESFS, 2014:
http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:52014SC0261
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The ESAs disclose a lot of quantitative data on the financial industry. Transparency
exercises are run on a regular basis, and the data items gathered and disclosed through
such exercises are defined in a way that allows a number of significant comparisons to be
made across time (e.g. on the risks and vulnerabilities of the banking sector).
Aspects to be improved
To increase the effectiveness and efficiency of SGs’ advice provided to ESAs, consideration
should be given to focus more resources on providing input in the early stages of ESA’s
regulatory work. Whenever possible, there could be an advantage in some SG members
being informally involved with the regulatory process as early as possible (see the case of
the pending EBA RTS on strong authentication and secure communication under PSD2).
There is a need for more explicit feedback from ESAs on the opinions published by the SGs,
for instance, explaining the reasons why a recommendation has not been accepted. A
system of tracking the effectiveness of SGs recommendations could be put in place. Such
a system could involve monitoring the extent to which SGs positions have or have not been
taken into account in ESAs final positions.
There is an important issue of SGs resourcing as many members do not have access to a
particular expertise from within their respective organisations. Dedicated resources could
be made available to SGs. Some national regulatory agencies (for instance, the UK’s
Financial Conduct Authority) establish research budgets for its stakeholder groups and this
has also been
the case for the EU’s Financial Services User Group.
Consideration should be given to enhancing the resources devoted to the SGs and their
Technical Working Groups. Financial resources could be allocated to organise informal
meetings among the SG members representing the civil society. Such meetings could
greatly enhance the effectiveness of the WGs.
There is a need to explore the scope for more systematic collaboration between the ESAs
SGs. The ESA SGs consist of a total of 120 people (1 group at EBA and ESMA each and 2
groups at EIOPA). Organising a close cooperation between these resourceful groups could
contribute to improving the quality of regulatory work of the three ESAs and the Joint
Committee. Joint submissions by the ESAs SGs should be considered especially in cases of
consultations proposed by the ESAs’ Joint Committee (only one joint submission so far, to
our knowledge).
To work effectively in the area of consumer protection and innovation, it is important that
there is more collaboration between EU consumer representatives within each SG.
III.
Adapting the supervisory architecture to challenges in the
market place
Question 27.
To what extent has the current model of sector supervision and separate
seats for each of the ESAs been efficient and effective? Please elaborate and provide
examples.
Question 28.
Would there be merit in maximising synergies (both from an efficiency and
effectiveness perspective) between the EBA and EIOPA while possibly consolidating
certain consumer protection powers within ESMA in addition to the ESMA's current
responsibilities? Or should EBA and EIOPA remain as standalone authorities?
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BEUC response
BEUC is in favour of a twin-peak model at the EU level, i.e. setting up a separate EU
financial conduct supervisor covering all retail financial services (see our response to
questions 6-7).
The rationale behind the Commission’s proposal to consolidate certain consumer
protection powers within ESMA is unclear, knowing that ESMA is competent only for
financial markets and investment issues, and not for other retail finance files (retail
banking, payments, savings, credit and non-life insurance). Is this proposal based on
good national supervisory practices? The Commission should justify any future changes
to the supervisory architecture and demonstrate how the proposals are expected to
enhance effective financial consumer protection across Europe.
IV.
Funding of the ESAs
Question 29.
The current ESAs funding arrangement is based on public contributions:
a)
should they be changed to a system fully funded by the industry;
b)
should they be changed to a system partly funded by industry?
Please elaborate on each of (a) and (b) and indicate the advantages and disadvantages
of each option.
Question 30.
In your view, in case the funding would be at least partly shifted to industry
contributions, what would be the most efficient system for allocating the costs of the
ESA's activities?
c)
a contribution which reflects the size of each Member State's financial industry
(i.e., a "Member State key"); or
a contribution that is based on the size/importance of each sector and of the
entities operating within each sector (i.e., an "entity-based key")?
d)
Please elaborate on (a) and (b) and specify the advantages and disadvantages involved
with each option, indicating also what would be the relevant parameters under each option
(e.g., total market capitalisation, market share in a given sector, total assets, gross
income from transactions etc.) to establish the importance/size of the contribution.
Question 31.
Currently, many NCAs already collect fees from financial institutions and
market participants; to what extent could a European system lever on that structure?
What would be the advantages and disadvantages of doing so? Please elaborate.
BEUC response
ESAs need an adequate and sustainable funding in order to meet ambitious supervisory
targets, including with regard to consumer protection. Unfortunately, the ESAs budgets,
which are already very modest, have faced cuts in the past years
20
.
20
https://eiopa.europa.eu/Publications/Other%20Documents/ESAs_2014-
41___Joint_ESAs_letter_to_EU_Council_Presidency_-_ESAs_Budget_2015_.pdf
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