The European Network of Credit Unions submitted its comment letter to the European Commission in response to its Consultative Document: Fitness Check on Supervisory Reporting. In its letter ENCU urged the European Commission to reduce regulatory burden by considering the size, complexity, and structure of credit unions when simplifying and streamlining the supervisory reporting requirements.
In particular ENCU recommended that the EC consider the differing rulebooks under which credit unions operate noting that many times those regulations are significantly more stringent than those operating under CRD IV and CRR. Further, given that credit unions are not-for-profit, member owned institutions run by volunteer boards and volunteer employees, that compliance burdens and costs often fall disproportionately on credit unions.
ENCU urged the EC to tailor any changes with an eye towards easing the compliance burden and reducing any costs associated with such changes.
A copy of the letter can be viewed here.