Changes to the Capital Requirement Directive

We do not believe a regulatory initiative such as the changes to the Capital Requirements Directive really addresses the major issue revealed by the financial crisis. The roots of the 2008 financial crisis are indeed clearly identified by now. Irresponsible mortgage lending to US households has been an initial trigger of the worst financial crisis since 1929. In turn, this irresponsible lending came largely from the quite recent development of the packaging of these loans through securitization, which - together with questionable accounting practices - enabled banks to take these loans off balance sheet. If these mortgage
loans had stayed 100% on the banks’ books, it is unlikely any “sub prime” crisis would have occurred, at least with this magnitude.

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