BBA has commented on what advice the European Supervisory Authorities should provide to the European Commission on the fundamental review of the Financial Conglomerates Directive (FICOD). It says the FICOD review must fit with the rest of reforms currently under way on shadow banking, systemically important financial institutions, and on bank structure, resolution and governance. It says regulation must avoid layering of reporting and capital requirements. (BBA Response to ESAs on FICOD Advice)