EU and US divergence on the 5% risk retention rules have missed an opportunity for harmonisation – it could lead to regulatory arbitrage.
That was the message from panellists at IFLR’s European Capital Markets Forum on April 14.
Comparing US rules under Dodd-Frank – in the proposal stage, and EU rules, speakers bemoaned the differences between the two.
“An opportunity has been missed,” said Michael Gallagher, head of structured debt GBM for Royal Bank of Scotland.
“The EU rules were around for a long time in some form, and are now in final form. The opportunity was there for the US to come along and...