Single Supervisory Mechanism Without Regulatory Harmonisation? Introducing a European Banking Act and a 'CRR Light' for Smaller Institutions

The Single Supervisory Mechanism (SSM) is widely acknowledged as being a milestone towards the creation of an effective transnational supervision in the Euro Area. Yet the SSM is far from being perfect. The European Central Bank (ECB), which is tasked with the supervision of all significant banks in the Euro Area, has to cope with a plethora of national rules as well as options and discretions that will be exercised at the Member State level. This creates inefficiencies. Simultaneously, European rules on banking regulation have become dispersed and hard to access. This paper therefore calls for the adoption of a single text, the "European Banking Act". To avoid overregulation, this act should include special requirements for small and medium-sized banks, or a "CRR light"