imagining better transparency September 21, 2012Posted by Bradley in : transparency , trackback
Corporate Europe Observatory critiques the EU’s policy processes in this video.
The video focuses on participation in expert groups, but there’s an imbalance in participation in later consultations also. Comments to the European Parliament’s consultation on market manipulation : lessons and reform post LIBOR/EURIBOR have been published here. As usual there are a large number of comments from trade associations and a small number from groups representing consumers.
There are some transparency issues (defects) with respect to the publication of these responses. There are three anonymous submissions. Although the GFMA seems to have tried to contribute to this consultation with its global principles document, which was addressed to Arlene McCarthy, the Committee’s rapporteur among others, and AFME clearly thinks the GFMA document was responsive to this consultation, the GFMA document does not appear in the list of comments. Also, the response of the Association of Foreign Banks states in answer to a number of the consultation questions “Please see our response to the UK Wheatley Review of LIBOR: initial discussion paper.” Presumably this was provided to the Committee, but it is not on the consultation page and is not accessible from the AFB’s website (which is generally opaque to non-members), or from the Wheatley Review web page which does not (yet?) show the comments made to that Review.
From the perspective of public transparency this isn’t ideal. In some ways I do have a preference for consultations where the full responses are published (if in fact they are), but this method of providing access to the comments does require a lot of time to wade through the responses. And this is made worse by the fact that some of the responses contain padding , are not precisely geared to this consultation (for example the response from Transparency International, although it does have some good stuff in it) or are designed not so much to provide information useful for the consultation as to create a good impression – pr rather than policy. But the fact of providing online access to comments does suggest that much more could be done. The consultation could link to the Transparency Register, and, in turn that Register could link to all representations the registered entities have made to EU institutions.