Who in Brussels will decide the future of Europe? On 18 July 2005, General Directorate Internal Market is holding a conference entitled "Exchange of Views on the Financial Services Policy 2005 - 2010"in the Charlemagne Building in Brussels.

On 18 July 2005, members of the European finance world will meet in Brussels at the invitation of the European Commission in order to discuss and agree the legislature's new "Financial Services Action Plan"for the years 2005 to 2010.

The General Directorate Internal Market is holding a further meeting to set the European legal framework and market conditions for banking, insurance and investment products. Consumer interests, like those of employees, the social sector or national rights are being granted few opportunities to be heard.

Just as they did in March of last year, about 240 members of the European and American finance world will meet in Brussels in order to receive the various reports of the "Groups of Experts" and discuss the Financial Services Action Plan for the coming years with Internal Market Commissioner McCreevy.

The key views of the committees of experts and the demands from Brussels for a united Europe are as follows: to cut down on national legislation, to transfer financial legislation to committees of experts ("Lamfalussy-Process") and to develop mechanisms for self-regulation. "Consumer (price) benefits" will be substituted for consumer protection. Social protection against over-indebtedness and investment losses is to be driven by sales information for consumers and small businesses. National checks and maximum harmonisation are intended to enable banks and insurance companies to operate without regard for the national law of the host country. People who have less should pay more ("risk-adjusted pricing" and Basle II). Trans-national sales are more important than national cultures in money transactions and "more" of everything is a good thing.

The legal barriers against over-indebtedness such as personal signature (a click of the mouse will be enough under the Consumer Credit Directive), the prohibition against usury, the prohibition against interest on interest, the supervision of lenders by banks (free availability of credit card loans in the Payment Directive) and the restriction on harmful risk investments with customer participation will all come to an end. The privatisation of Sparkassen (German mutual savings banks) and the prohibition against state subsidies for financial services in problem areas and for the socially disadvantaged will also form part of the process. The model, and it is being aggressively promoted, is neo-liberal. Even in the wake of the crash of the New Economy and the record levels of over-indebtedness and investor deception, the market is seen as the solution.

Both national and parliamentary controls have capitulated in the face of social and economic policy wrapped up in technology. The European Parliament has reduced its responsibility for Directives to a right to raise objections in the "Lamfalussy-Process". In the same way, the other General Directorates such as Consumer Protection, Social Policy and Business have pulled out. Who is represented by whom is determined by DG Market itself. It thus keeps the choice of conference participants to itself, likewise membership of the committees of experts. This even applies to the representatives of consumers and small businesses. The political triangle of Great Britain, the Netherlands and Ireland continues to set the tone. There will probably be only two consumer representatives - the representative from the British media group, Which? and the British chair of the Financial Users Committee, on which consumer representatives are in a minority. The paper setting out a critical analysis of the process as a whole, which FIN-USE 2004 passed to the Commission in October as the basis for further discussion, is not cited in the Review of Documentation and nor is the FIN-USE Committee itself among the Groups, listed as involved with Post-FSAP. Reference is instead made to FIN-Net, the network of bank ombudsmen. French, Italian and German versions are only available for the summary of the 2004 Report, which will deter most lay people. No money was allocated for translation.

Similarly, there is an absence of references to the research carried out for DG Consumer Protection into national consumer law on financial services, and the principles drawn from it for the development of a controlled, culturally-adapted European financial services legislation (see www.money-advice.net/ccd)

Will people in Brussels congratulate themselves on the progress they have made in creating a European Finance Sector in which Finance Ministers, banks and bank supervisory authorities negotiate between themselves and in which social policy, consumer policy, small business policy, regional policy and legal policy are sidelined? If money rules the world, the world should react to money.

The programme points in the wrong direction. DG Market appears alone. Alexander Schaub and Charlie McCreevy will have pleasant conversations with bank supervisors and bankers, in which the comment by an American insurance company representative, to the effect that without their own supervision they are disadvantaged in comparison with banks across the Atlantic, because a supervisor is the best lobby in Washington, also has a certain justification in Brussels.

The third High Level Panel will thus exclude consumer representatives from discussions of the new priorities, which are "asset management and consumer transactions". In addition, both British panel-members nominated as consumer representatives will have the opportunity of spending 45 minutes with the General Director of BMP, the representative of the Scandinavian banks and a representative of the insurance industry in global discussions about financial services. Will the representative from FIN-USE again be deprived of a hearing on this occasion?

Quite clearly, the Commission sees banking practice of the future, following the programme, as a matter for financial service providers and their supervisory agencies. In that context, it should not be forgotten that the task of supervisory agencies in the financial services sector is clearly defined in all countries as to ensure the well-being, and thereby the security and continued existence of these enterprises.

Under German law, these agencies have no explicit responsibility for consumer protection. That role is the domain of civil law, the courts, money advisors, financial advisors, lawyers, trade unions, consumer organisations, social welfare agencies and urban development programmes. What is known in the USA as "Community Finance", and forms an inseparable part of the process of financial legislation, is completely absent from Brussels.

For those who do not wish to engage in the task of going through the whole programme as well as the papers of the "expert" groups, we have put together a list of participants obtained from the Commission, from which we have removed the names and kept only the companies and organisations they have represented in this process since 1999. Those appearing twice also had double representation. The list of names associated with it is at iff. No-one has been left out. If you see that a body has been omitted, it is because it has been omitted from the democratic process in Brussels. The following five organisations, which will operate as a special group in determining the banking legislation of the future, are perhaps significant: Banco Bilbao Vizcaya; LeaseEurope/Euro-Finas; Deutscher Sparkassen- und Giroverband; Deutsche Bank AG; European Banking Federation; Barclays Bank PLC.

List of Actors in the Process of European Financial Legislation and Post FSAP Planning according to the Internet Sites of the Commission

ABN AO, ABN AO Bank N.V., ACME, AEGFP, AEGON N.V. - Group Business Development, Aegon; , AIB Investment Managers, Allianz Group European Affairs Office, Allianz; , Alpha Insurance Company, AMF Pension, Asociación de Mercados Financieros, Assicurazioni Generali, Association Française de la Gestion Financière, Association Française des Entreprises d'Investissement AFEI, Association of British Insurers, Association of British Insurers ABI; , Association of Private Client Investment Managers and Stockbrokers APCIMS, Association of Private Client Investment Managers and Stockbrokers APCIMS; , Associazione Bancaria Italiana ABI, Associazione Italiana fra le Società per Azioni ASSONIME, Associazione Italiana Intermediari Mobiliari ASSOSIM, ASSOGESTIONI, Assogestioni; , AVIVA plc, AXA GIE, AXA Insurance - Business Operations, AXA Ireland; , Banca Intesa; , Banco Bilbao Vizcaya, Banco Bilbao Vizcaya Argentaria, Banco Bilbao Vizcaya Argentaria, Bank Austria, Barclays Bank, Barclays Bank PLC, BBA and EBIC, BIPAR, BNP PARIBAS, BNP Paribas, BNP Paribas, BNP Paribas Asset Management, BNP Paribas; , BNP Paribas; , British Bankers Association BBA, Caja de Madrid, CDC IXIS, CEBS , Ceská Asociace Pojist'oven, CESR expert group on investment management, Comité européen des assurances - CEA, Commerzbank AG, Committee for Economic and Monetary Affairs; European Parliament, Committee for European Securities Regulators CESR, Committee of European Banking Supervisors CEBS, Committee of European Securities Regulators CESR, Committee of European Securities Regulators CESR, Committee of European Securities Regulators CESR; , Committee on Economic and Monetary Affairs in the European Parliament ECON, Confederation of Nordic Bank, Deutsche Bank AG, Deutsche Bank Asset Management, Deutsche Börse, Deutsche Börse AG, Deutscher Sparkassen- und Giroverband, Deutsches Aktieninstitut DAI, Deutsches Aktieninstitut; , DG ECFIN, DG ECFIN European Commission, DG Internal Market, DG Internal Market and Services, DG Internal Market and Services, DG Internal Market and Services, DG Internal Market and Services, DG Internal Market Financial Markets; , DG Internal Market Head of Unit Securities Markets and Investment Services; , DG Internal Market;, DG Market, DG Market, DG Market, DG Markt.C.03, DG Markt.C.03, EACB, ECB, ECON Committee of the European Parliament, EFRP, ERSTE BANK AG, ESBG - European Saving Banks Association, EURESA-LIFE, Euroclear, Euroclear, Eurofi, EuroMTS, Euronext, Euronext, Euronext;, Euronext-LIFFE, European Association of Listed Companies and Air Liquide, European Association of Listed Companies EALIC, European Banking Federation, European Banking Industry Committee EBIC; , European Banking Supervisors CEBS, European Central Bank ECB, European Central Bank ECB, European Central Bank ECB; , European Commission, European Commission, European Commission, European Commission, European Commission, European Commission, European Commission, European Federation of Building Societies, European Financial Reporting Advisory Group EFRAG;, European Financial Services Roundtable EFR Aviva, European Insurance and Occupational Pensions Supervisors CEIOPS , European Insurance and Occupational Pensions Supervisors CEIOPS., European Mortgage Federation, European Private Equity and Venture Capital Association EVCA;, European Securities Regulators CESR, European Securitisation Forum, EVCA, Fédération Française des Sociétés d'Assurance FFSA, Fédération Française des Sociétés d'Assurance FFSA; , FEFSI, FEFSI/EFAMA, FERI - Fund Market Information Ltd, FFSA and CEA, Fidelity Investement Services Limited, Financial Services Committee FSC, FIN-USE, Fortis Bank, Fortis; , FSC Subgroup on Supervision , Gartmore, Goldman Sachs, Goldman Sachs International, Groupe Consultatif Actuariel Européen, Groupe ODDO-Pinatton, Groupe ODDO-Pinatton, Groupe ODDO-Pinatton, ING Poland, Insurance House, International Primary Market Association IPMA, International Securities Market Association ISMA, International Swaps and Derivatives Association ISDA, Investment Management Group Linklaters Loesch, ISDA, J. P. Morgan Fleming - Asset Management France, KBC Bank, La Caixa, La Mondiale, LeaseEurope/Euro-Finas, LIBA, Lloyds TSB Bank Plc, London Investment Banking Association LIBA, London Investment Banking Association LIBA; , London Stock Exchange, MAPFRE, Merril Lynch; , Merrill Lynch, Merrill Lynch Investment Managers Limited, Merrill Lynch Mercury Asset Management, Morgan Stanley International Ltd, Morgan Stanley International Ltd., Münchener Rückversicherungs-Gesellschaft, Nordea, Nordea Bank AB publ, Nordea Cash Management, Nordea Legal Service, Nordea; , Northern Trust, Pension and Asset Management / Philips International, PZU SA; , Rabobank Cash Management, Rabobank Nederland, Realkreditrċdet The Association of Danish Mortgage Banks, San Paolo IMI Bank, San Paolo IMI Wealth Management, San Paolo IMI Wealth Management; , Santander Central Hispano Asset Management, Shell Pensioenfonds Beheer, Société Générale, Swedish Insurance Federation, The European Consumers' Organisation BEUC, Threadneedle Investments, UBS AG, UK Financial Services Authority FSA; , UK IMA, UK TREASURY FINANCIAL SECRETARY, Unifortune, Union Asset Management - Holding AG, Union Asset Management; , Universidad Complutense de Madrid, Universität Wiesbaden Fachbereich Wirtschaft, Université Lyon 3 Chaire Jean Monnet, BEUC / Which? LTD UK Consumer Association , BEUC Bureau Européen des Unions de Consommateurs, Committee of European Securities Regulators CESR, DG Market European Commission, European Commission , European Commission , Federation of European Risk Management Associations, University of Athens Chairman of the Hellenic Capital Markets Commission; , University of Athens Hellenic Capital Markets Commission, Verband unabhängiger Vermögensverwalter VUV, VVÖ, Westdeutsche Landesbank, Westdeutsche Landesbank