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The ABBL takes due note of the 3 consultation papers on Shadow Banking. The association would like to first warn that the concept of “shadow” does not necessarily mean that the activities are not regulated or supervised. The association has identified in many parts of these 3 dense documents areas that are either already regulated or will soon be regulated at EU level. In addition, the association regards this exercise as the completion of the regulatory agenda started in 2009. Indeed, if there are now ideas to regulate, supervise and organise what is in the shadow it may also mean that the origin of the shadow is already well regulated. This also means that the regulatory ideas envisaged should be understood as filling the gaps left by the current new regulatory environment and may be...
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