銀行同盟の建設と進展

―銀行規制・監督の調和への挑戦―

抄録

This paper aims to examine the institutional framework on EU’s Banking Union project through political economy approach. Current Banking Union consists of three pillars, namely, SSM (Single Supervisory Mechanism), SRM (Single Resolution Mechanism) and a Common DGS (Deposit Guarantee Schemes). The SSM has already started from 4 November 2014. Then, the swift implementation and negotiation are implementing in 2014-15 for constructing the SRM. In addition, the Common DGS shall be also tackled with as another common backstops in protect for people’s deposits.

In Genuine Economic and Monetary Union launched in 2012, the current Banking Union project is substantial in context of the history of European Monetary Integration. In needs for the ‘weakening’ the link between banking crisis and sovereign debt crisis among Eurozone member states, the solution through the Banking Union is beneficial and inevitable. However, there are some obstacles to make the banking regulation single. As far as the structural aspect, ⑴ there are differences of financial systems in member states, ⑵ there is an inconsistency between continental European style and British style on banking regulation and supervision.

In part Ⅱ, we find the reasons and urgent needs for SSM and SRM through the trace of Eurozone crisis after US sub-prime mortgage loan problem and Global Financial Crisis. And we examine the framework and development on SSM, in particular, through the viewpoint of French and German financial systems. In addition, we suggest expectations and challenges for the implementing of SRM as a next stage. There are four tools; ⑴ Sale of business tool ⑵ Bridge institution tool ⑶ Asset separation tool and ⑷ Bail-in tool. We cannot overlook that these tools contain the traditional ones such as bridge institution as a ‘bail-out’, so we should think about the mixed type both of ‘bail-out’ and ‘bail-in’ on the analysis of SRM.

And in part Ⅲ, we shed light on the harmonisation of banking supervision in EU and its effect on international standard constructed by FSB (Financial Stability Board). Particularly, we try to focus on EBA (European Banking Authority) in London which would play an essential role between Eurozone and Non-Eurozone as an institution of ESAs(European Supervisory Authorities).

Lastly, we suggest the common concept between European Banking Union and FSB’s Key Attributes to harmonise the regulatory and supervisory policies in advanced economies. So the elements in Banking Union would be the key basement in international standard in future.