But as experience has taught us that it is all but impossible to draw up an exhaustive list of criteria covering all eventualities, the final decision must rest with the supervisors. And, of course, banks should ultimately also have the opportunity to reject their classification as such an institution. Now let’s turn to “how”. There are basically two potential ways of improving proportionality here.
First, we could take a small-scale approach and introduce simplifications and exceptions for individual rules. Second, we could create a whole new framework that is specifically tailored to small banks and low-risk institutions. The second solution would be further-reaching and clearercut. But at present, the majorities in Europe appear to favour the small-scale solution. And then we still have to consider “what”.