This is being debated under the label of proportionality – or, more precisely, the lack of proportionality. I am here today to give you my opinions on this issue. 2. Where do the problems lie?
Complexity and compliance  An expert opinion on proportionality 1 commissioned by the Federal Association of German People’s Banks and Raiffeisen Banks can be singled out as a particular driver of the increased political attention being given to the debate on proportionality over the past few months.