On November 22, 2024, the IIF submitted a response to the Targeted Consultation Document, Assessing the Adequacy of Macroprudential Policies for Non-Bank Financial Intermediation (NBFI) published by the Directorate-General for Financial Stability, Financial Services and Capital Markets Union at the European Commission. The IIF response highlighted the need for:

• A conceptually converging (but not necessarily identical) approach to NBFI macroprudential policy and tools across EU jurisdictions in order to promote financial stability.
• A focus on NBFI activities that (i) involve maturity transformation or the provision or transformation of liquidity and (ii) are not subject to liquidity management tools and leverage limits or supervisory reporting of leverage and take into account any potential procyclical or countercyclical impacts.
• Cross-border regulatory and supervisory coordination.
• The avoidance of macroprudential policies and tools that give banking organizations and NBFIs subject to prudential measures for liquidity and leverage a ‘gatekeeper’ role in mitigating the risks of NBFI activities that are not subject to those measures.