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]]>EBF COMMENT
EBF comments on the new EU Retail Investment Strategy
BRUSSELS, 24 May 2023 – In keeping with the objectives of the CMU Action Plan, the European Banking Federation (EBF) notes the publication of the EU Retail Investment Strategy as a significant opportunity that, if properly designed, has the potential to increase access to EU capital markets by retail investors while ensuring adequate levels of investor protection. In this context, the EBF has consistently expressed concerns about the possibility of unforeseen disruptions arising from extensive measures, such as a complete prohibition on commissions, and emphasized the potential adverse effects on vital aspects such as the accessibility of comprehensive and high-quality advisory services.
We remain appreciative of the Commission’s decision not to propose a full ban on commissions, recognizing that such a move would have a potential disruptive impact for the European financial sector and for the access to financial advice for European households. However, as we are currently undertaking a comprehensive analysis of the text to understand the full scope and impact of the changes put forward by the Commission, we note that key aspects of the proposals are unprecedentedly far-reaching in nature and give rise to substantial concerns that such a disruptive impact is still likely to materialize, with clear negative impacts that would not be conducive to an improved customer journey or better outcomes for retail investors. We are particularly concerned that the cumulative and combined effect of the totality of measures put forward in today’s proposal, such as a prohibition on commissions in relation to products sold in the execution-only service or new drastic product governance requirements, would produce extensive effects that can limit fair competition between advisory models, resemble regulatory intervention on both price setting and product offering, and even yield outcomes akin to those of a full ban on commissions at least in certain markets.
An EBF spokesperson commented: “The EU Retail Investment Strategy is a unique opportunity to promote access to financial investments by retail clients while ensuring a high level of investor protection. Striking the right balance between simplification, resilience and attractiveness will be key, not last to unlock the long-term funding needed to finance the transition. In order to serve retail clients needs and to ensure that EU capital markets continue to be competitive, it is important that the EU-framework allows retail clients access to different types of investment services (advisory and non-advisory) as well as access to different types of investment products. This is why, at the present state, we are particularly concerned that the combined effect of the far-reaching changes introduced today, while not conducive to a full ban on commissions, may still produce significantly disruptive impacts for the European financial sector. On our part, as the voice of the banking sector, we remain open to supporting the discussion at European level and working with all stakeholders to ensure that the key objectives of the Retail Investment Strategy are fully met.”
For more information:
Ruta Barthet, Senior Media and Communications Officer, r.barthet@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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Derivatives Clearing – Review of the European Market Infrastructure Regulation and accompanying changes to other Regulation and Directives (EMIR/CRR/MMFR and UCITD/CRD/IFD)
BRUSSELS, 15 May 2023 – The European Banking Federation (EBF) welcomes the legislative package set forth in the communication by the European Commission “A path towards a stronger EU clearing system’’ of December 7th, 2022 to support the development of a better integrated and more attractive clearing landscape in the EU.
In the proposal, the Commission has taken important positive steps to achieve such objectives, including the removal of equivalence as a pre-condition to the availability of the intragroup transaction exemption and the streamlining EU CCPs supervisory procedures for launching new products and model changes.
At the same time, against this background, EBF members emphasize that the proposal also features substantial and highly complex elements, which, if incorrectly and inappropriately addressed, may lead to unforeseen and extensively adverse effects on the competitiveness, resilience and attractiveness of European financial markets and their financial institutions.
Hence, with a view to ensuring the highest quality in legislative outcome and to promote a comprehensive and thorough discussion that may be as evidence-based as possible on the reform of EMIR rules and other critical pieces of regulation going forward, EBF experts the following key observations.
For more information:
Jacopo Borgognone, Financial Markets – Financing Sustainable Growth, j.borgognone@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
The post EBF Analysis: Derivatives Clearing – Review of the European Market Infrastructure Regulation and accompanying changes to other Regulation and Directives (EMIR/CRR/MMFR and UCITD/CRD/IFD) appeared first on EBF.
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EBF Position on MIFIR Review
BRUSSELS, 12 January 2023 – The European Banking Federation (EBF) is a strong supporter of deepening the Capital Market Union and believes that the MiFIR review proposal presented by the European Commission (EC) on November 25, 2021 is critical for increasing the competitiveness of financial market actors operating in the EU-27 and the attractiveness of the EU’s regulatory framework. However, the EBF has concerns about several of the MiFIR reform proposals, which were not subject to proper analysis or impact assessments, making it difficult to assess their impact and potentially leading to unintended consequences for investment firms, clients, and the EU capital market as a whole.
- Consolidated Tape and Handling Increasing Market Data Costs: The EBF supports the EC’s proposal to establish a consolidated tape (CT) but suggests some adjustments be made and for ESMA’s recommendations to be included in binding EU legislation. The EBF also highlights that the creation of a CT may not solve the issue of increasing market data costs.
- Need for a Calibrated CT: EBF members generally support a well-calibrated consolidated tape, but the CT data needs to be of the highest quality to guarantee data excellence and dependable retrievability at all times. This includes well-calibrated deferrals in post-trade transparency obligations and not including the MIC code of the SIs, to avoid unintended consequences.
- Asset Class Priority and Scope of Data: The EBF suggests prioritizing the establishment of a CT for equity (also jointly with ETF instruments) over a CT for bond instruments, and for a proper cost-benefit analysis to be conducted for derivatives. The scope of data should include pre and post-trade data for shares and ETFs, and post-trade data for bonds as close as possible to real-time.
- Mandatory Contribution: The EBF welcomes the mandatory contribution submitted free of charge by trading venues and approved publication agreements to the CT provider. They also recommend a fair and bearable revenue sharing system for data contributors, to promote further harmonization of data formats, quality, and standards.
- Importance of MiFIR Review Proposal: The EBF believes that the MiFIR review proposal is critical to increase the competitiveness of financial market actors operating in the EU-27 and the attractiveness of the EU’s regulatory framework. They encourage proper analysis and impact assessments for all proposed reforms to ensure the EU capital market is not negatively impacted.
For more information:
Marta Morellato, Financing Sustainable Growth team, m.morellato@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
The post EBF Position on MIFIR [January 2023] appeared first on EBF.
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EBF Position on MIFIR Review
BRUSSELS, 25 April 2022 – The European Banking Federation (EBF) is a strong supporter of deepening the Capital Market Union to enable financial markets to play a stronger role in light of the EU-27 financing challenges. The review proposal presented by the European Commission (COM) on 25 November 2021 is of critical importance to increase the competitiveness of financial market actors operating in the EU-27 and the attractiveness of the Union’s regulatory framework.
With these objectives in mind, the EBF finds it regrettable that several of the MiFIR reform proposals both for the equity and the non-equity transparency regimes are based on expected benefits that were neither subject to an in-depth analysis nor to a comprehensive impact assessment. This makes the impact of the proposals very difficult to assess and could lead to unintended consequences for investment firms, clients and the EU capital market as a whole.
In more details,
- EBF supports a well calibrated consolidated tape. However, we would like to highlight that the creation of a CT will not solve the issue of increasing market data costs.
- On equity transparency, the EBF would like to highlight the need for ensuring competitiveness and attractiveness of EU equity markets. We believe the current proposal regarding equity SI will create a three-tiered set of mid-point trading rules exacerbates the existing issues of complexity afflicting equity markets in Europe and damages investors’ perceptions of the quality of the market’s structure.
- On non-equity transparency, there is a need for well-calibrated deferrals taking the needs of clients and liquidity providers into account. In this context, both price and volume need to be deferred for longer periods than proposed by the Commission (i.e. endo of the day). We also support to keep the the size specific to the instrument (SSTI) as it is since it protects SIs against undue risks.
- Regarding payment for order flow, MiFID II already provides for a broad toolkit of regulatory measures in this scope (i.e. well calibrated provisions on conflict of interest, inducements and best execution).
Finally, our members’ experience from both MiFID I and MiFID II/MiFIR shows that there should be a minimum of at least 18 months from the time both Level 1 and Level 2 are published in the “Official Journal of the European Union” until they apply
For more information:
Paulin Guérin, Senior Policy Adviser Financing Sustainable Growth, p.guerin@ebf.eu
Marta Morellato, Financing Sustainable Growth team, m.morellato@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
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EBF Position on EC Consultation on options to enhance the suitability and appropriateness assessments
BRUSSELS, 29 March 2022 –Last week, the European Banking Federation (EBF) expressed concerns regarding the European Commission’s proposals for a single assessment regime for retail investors and the provisions of a personal asset allocation strategy, transferable to any financial intermediary. The proposals could hinder innovation and competitiveness and have the potential to ultimately lead to dangerous concentration of risks.
- This approach would introduce unnecessary rigidity for investment firms, negatively impacting clients: a unique standardized questionnaire would not be able to address the differences among types of retail clients and would likely lead to a flattening of the quality of investment advice.
- Rules on personalized asset allocation strategy should not foresee standardized investor profiles: investment service providers already have in place classification systems based on the current legislation, available products, research and investment strategies. Any change to the system would cause administrative burdens and extra costs hindering EU investment institutions’s competitiveness
The weaknesses of the current regime are not clearly explained and therefore the rationale to modify it and the benefits it would bring are not obvious The EBF supports a high level of investor protection which requires avoiding information overload while ensuring that pre-contractual information is well understood by retail clients. To this end, the EBF supports a simplification of the investor protection rules in combination with measures to increase clients’ level of financial literacy.
For more information:
Paulin Guérin, Senior Policy Adviser Financing Sustainable Growth, p.guerin@ebf.eu
Marta Morellato, Financing Sustainable Growth team, m.morellato@ebf.eu
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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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Over the past year, the European banking industry has been hit by volatile markets, worsening economic conditions and business continuity challenges. As a result, lenders have moved more quickly to build real-time data and analytics into their credit risk systems.
Join industry experts as they explore the impact across the banking landscape and how default assessment plays a pivotal role in the recovery:
- The general trend in credit quality at Europe’s banks
- The nonperforming loan market: Pandemic versus global financial crisis
- Asset quality deterioration: Key constraints and challenges
- How credit score distribution differs between 2019 and 2020
- Key lessons from trade credit data and alternative data sets
WATCH THE FULL WEBINAR
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DOWNLOAD PRESENTATIONS
Gonzalo Gasos
Senior Director of Prudential Policy & Supervision
European Banking Federation
MODERATOR
Ben Meggeson
News Desk Manager – European financials, S&P Global Market Intelligence
ORGANISERS
S&P Global Market Intelligence
S&P Global Market Intelligence integrates financial and industry data, research and news into tools that help track performance, assess credit risk, understand competitive and industry dynamics, generate alpha, identify investment ideas, and perform valuation. S&P Global Market Intelligence is a division of S&P Global (NYSE: SPGI). For more information, visit www.spglobal.com/marketintelligence. Twitter handle: @SPGMarketIntel
European Banking Federation
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from 45 countries. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
The post Managing Credit Risk during the COVID-19 Crisis & Recovery Phase in Europe appeared first on EBF.
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European Commission Consultation on the establishment of a European single access point (ESAP) for financial and non-financial information publicly disclosed by companies: EBF response
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BRUSSELS, 15 March 2021 – The European Banking Federation has responded to the European Commission’s consultation on the establishment of a European single access point (ESAP) for financial and non-financial information publicly disclosed by companies.
Key message:
Why is ESAP needed?
- Currently published data are not always easily accessible, or easy to find, which increases the cost of access
- Increase visibility of some entities (SMEs, non-listed) that need to attract financing and create new investment opportunities for investors;
- Help building the ESG data based on EU legislation and voluntary fillings;
ESAP is seen as:
- A tool to centralize public disclosures, required by the EU legislation or voluntary filled in;
- Opportunity for entities not in the scope of EU Regulation or information not mandatory required to be reported on a voluntary basis;
ESAP should not:
- Impose new disclosure obligations or timelines. New disclosure obligations need to be introduced in the EU legislation first (make sure EU legislation is fit for purpose and mandatory public disclosure are useful ) It is therefore important to get the scope of any EU legislation right in the first place;
- Impose any new significant burden (information should only be reported once;
ESAP should:
1. Start small, think big:
- Initially limited number of key EU legislation in scope (e. g. Transparency Directive, Accounting Directive, Prospectus Directive, revised Non-Financial Reporting Directive and data required Sustainability-Related Disclosure Regulation and Taxonomy Regulation)
- Adopt “look through” approach for legislation in scope in case the datapoints should be further limited in the initial phase (e.g. key ratios or KPIs from NFRD or other regulations)
- o at a later stage, product information (prospectus in particular) should also be made available on the ESAP but this should not be a priority in the short term
2. Pull in existing public registers (interconnect existing MS databases)
3. Ensure information is easily accessible in user friendly format
4. Ensure information quality in a comparable and machine-readable manner including those provided on a voluntary basis (common standards and structure)
5. Provide access to raw data
6. Include data source
7. Be publicly funded and governed as it is a public good. In this spirit, we believe that access to ESAP should be free for end-users.
Find the EBF response to this consultation by clicking the ‘full document’ button below:
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FOR MORE INFORMATION:
Sustainable Finance page on the EBF website: CLICK HERE
Denisa Avarmaete, Senior Policy Adviser, Sustainable Finance, EBF
d.avarmaete@ebf.eu
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ABOUT THE EUROPEAN BANKING FEDERATION:
The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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]]>FROM THE EUROPEAN BANKING FEDERATION:
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BOOSTING EUROPE
EBF recommendations for the 2019-2024 legislative policy cycle and beyond
BRUSSELS, May 2019 – To provide ideas and recommendations to policymakers, regulators and experts on the role of banks in the European Union for the next five years and beyond the European Banking Federation has published a manifesto that outlines the main regulatory priorities for the banking sector in the context of the upcoming 2019-2024 legislative policy cycle.
Click to download BOOSTING EUROPE as pdf.
As the voice of European Banks, the EBF and its members remain fully committed to supporting a more competitive and cohesive EU in the context of Europe’s great diversity. We believe that without a united and coordinated Europe, the most likely outcome would be more fragmentation, more protectionism and therefore underperforming economies to the detriment of citizens. The EBF is committed to help in supporting European economies so that European businesses and citizens are better served by banks. We have set out in this document the sector’s recommendations to address the key challenges Europe is currently facing.
Key recommendations:
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Banks as responsible partners to businesses and consumers
- Connect environmental, societal and financial goals
- Find new drivers to increase sustainable investments
- Financial literacy should be promoted as we believe it is an essential factor of the EU economic success
- Put more efforts in the fight against Financial Crime
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Build a true Digital Single Market
- EU’s competitiveness and consumer protection in the digital economy should be an EU’s top priority
- Adopt a holistic approach towards an EU data economy: data access and data sharing should be considered in a broader context than financial services
- Conduct a digital “fitness check” to grasp consumers’ and market participants’ expectations more thoroughly and guarantee that the legislation is fit for purpose in the digital era
- Banks should be seen as an indispensable partner for the completion of a truly Digital Single Market
- Deepen and upgrade cyber-security standards in the EU
- Enhance actions to address the social impact of digitalisation
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Enable banks to better serve the EU’s economy
- An appropriate transposition of Basel4 rules to avoid disproportionate increases in capital requirements for European banks is mandatory
- Remove the remaining obstacles on capital and liquidity circulation and reset the Capital Markets Union
- Maintain a diversified banking landscape
- Ensure a proper balance in taxation and tax compliance
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Achieve a stable and efficient regulatory framework
- Conduct a thorough analysis of the existing EU regulatory framework
- Complement this analysis with an in-depth examination of level playing field issues with non-bank competitors
- Address inefficiencies, overlaps and level playing field issues before proposing new regulations
To read the full document click on the link below or on the image above.
For more information:
Olivier Thomas, Public Affairs Representative
o.thomas@ebf.eu
+32 2 508 3712
Media contact:
Raymond Frenken, Head of Communications
r.frenken@ebf.eu
+32 2 508 3732
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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The post Boosting Europe – EBF recommendations for the EU 2019-2024 legislative cycle and beyond – manifesto appeared first on EBF.
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