What do the statements on the state of SPoR compliance mean for those relocating or starting the process?
The ECB in its role as the lead in the SSM pillar of the Eurozone's Banking Union uses various channels to communicate its supervisory expectations, both to financial services firms but also the national competent authorities (NCA). The ECB-SSM is the ultimate decision-making authority in relation to authorising the application for banking licences and/or variation or extension of regulatory permissions that have been submitted to a NCA for those looking to conduct banking activity in or through the Eurozone. So when the ECB-SSM's Chair of the Supervisory Board, Danièle Nouy, reports to the European Parliament's Economic and Monetary Affairs Committee her statements, such as those in her testimony of 9 November 2017 and SPoR compliance are noteworthy and of supervisory relevance. This Client Alert assesses Chair Nouy’s statements and how these will affect firms and their compliance with the SPoRs or cause some to take remedial action.