Consultation on streamlining the Banking Union's Single Rulebook for supervisory investigations closes 15 September 2017.
As most market participants and indeed most supervisors across the EU had the summer holiday season in mind, the European Central Bank (ECB) acting in its role within the Single Supervisory Mechanism (SSM) of the Banking Union published a consultation on its draft "Guide to on-site inspections and internal model investigations" (the OSIIM Guide). The consultation period commenced on 27 July and runs until midnight CET on 15 September 2017. This is quite a compact timeline given most relevant persons' calendars and the fact that this is an "open consultation", i.e., interested parties can comment on the whole breadth of the document. This Client Alert assesses the contents of the OSIIM Guide, how this development fits into wider EU and Eurozone specific workstreams and how, when compared to other SSM Guides 'qua rulebooks', this might affect Banking Union Supervised Institutions (BUSIs) to whom the OSIIM Guide's provisions are addressed. Further coverage on this important development will follow once the final version of the OSIIM Guide is available.