MALTA, 5 May 2017 — European banks, through the Board of the European Banking Federation, today reaffirmed their commitment to supporting the European project through actively and responsibly financing businesses and households. The Board welcomed continued evidence of easing bank credit standards and increasing loan activity in the euro area, as demonstrated again in the first quarter by the quarterly Bank Lending Survey of the European Central Bank.
Given the particular significance of bank finance for Europe’s economy the EBF Board called on national and European policymakers for proper calibration when it comes to the finalisation of the wide range of regulatory measures still currently under discussion in the European Union. This is necessary so that banks can continue their financing commitment and support growth and jobs.
“We need to make sure that the international competitiveness of the European banking sector is not damaged. It is up to policymakers now to finalise the regulatory agenda and strike the right balance, avoiding undue impact on the financing of households and companies while ensuring the development of a safe, sustainable and competitive European financial services industry that benefits all our economies.”
Customers expect banks to protect their personal data. Data protection is at the core of trust in financial institutions. While European banks fully embrace innovation in their services and value competition in the market, the Board of the EBF warns that an inappropriate changes of proposed technical standards for electronic payments would put at risk the integrity of customer data, jeopardises the level playing field in European payment services and places a disproportionate burden on banks in the implementation of unnecessary technical solutions.
The Board calls on the European Commission to adopt – without amendments – the delegated act proposed by the European Banking Authority (EBA) for electronic payment services under the second European Payment Services Directive, known as PSD2. Deviating from the EBA recommendations would clearly go against the objectives of enhancing consumer protection and improving security of payment services across the European Union.
Through the Board of the EBF European banks reaffirm their commitment to serving Europe’s economy and to working with households and businesses – including SMEs – on their finances.
National and European policymakers need to recognise that banks are held back from fully delivering on this commitment as long as they continue to face regulatory uncertainty.
Particular sources of concern for banks are the leverage ratio; the implementation of the minimum requirement for own funds and eligible liabilities (MREL); the Net Stable Funding Ratio (NSFR); and the Fundamental Review of the Trading Book (FRTB). Financing of the European economy can be substantially impacted if these are not carefully and proportionally calibrated.
The Board calls on EU policymakers to agree the EU Risk Reduction Package in a way that respects the balance between economic growth and financial regulation. European banks generally see the package as an opportunity to make regulation more proportionate, less burdensome and more manageable.
However certain elements of the package, in particular those regarding capital requirements, overlap with measures currently under discussion at the Basel Committee on Banking Supervision. The Board calls on policymakers to put on hold EU decisions on these measures until international decisions on the Basel IV framework have been finalised.
Addressing the global discussions in the Basel Committee, the Board of the EBF continues to fear that Basel IV could have significant negative consequences for bank financing in Europe if it is adopted with ill-calibrated parameters, in particular an output floor. The EBF Board strongly believes that European policymakers should only support an agreement on international standard if it is not detrimental to the banks’ capacity to finance businesses and households and hence does not jeopardise European growth perspectives.
Furthermore the Board calls on European policymakers to fully take into account the specificities of EU bank finance as opposed to the structure of financing in the United States, particularly regarding mortgages and corporates.
While the Board recognised the significant progress being made by the Single Resolution Mechanism (SRM) it noted the implementation of the full range of measures included in the SRM requires careful assessment of the potential impact and unintended effects on the EU economy. The Board highlighted the importance of building a constructive dialogue between the industry and the Single Resolution Board at a critical moment in its development.
Beyond the most urgent topics on the regulatory agenda, the Board also discussed longer-term topics such as the upcoming negotiations between the EU and the United Kingdom on its EU membership and the pending discussions on future cooperation between the EU27 countries and the UK. With regards to the EU plans for creating a Capital Markets Union, the Board unanimously agrees that the European Commission needs to develop a more ambitious approach, capital market financing being needed going forward to finance the economy as a complement to bank financing.
While in Malta the European Banking Federation and the Malta Bankers’ Association organised a joint conference on key issues affecting smaller European banks.
Hosted at the Malta Financial Services Authority the conference addressed the need for proportionality in regulation; digitalisation; and unintended constraints to correspondent banking, with the participation of the European Banking Authority, the European Commission and the European Central Bank. Prof. Edward Scicluna, Finance Minister of Malta, which currently holds the presidency of the EU, closed the conference with a reflection on the need to fine-tune EU regulation for banks.
Raymond Frenken, Head of Communications, +32 496 52 59 47, r.frenken@ebf.eu
The European Banking Federation is the voice of the European banking sector, uniting 32 national banking associations in Europe that together represent some 4,500 banks – large and small, wholesale and retail, local and international – employing about 2.1 million people. EBF members represent banks that make available loans to the European economy in excess of €20 trillion and that securely handle more than 300 million payment transactions per day. Launched in 1960, the EBF is committed to creating a single market for financial services in the European Union and to supporting policies that foster economic growth.
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]]>Financial markets are global, market actors are competing on a global level. Regulation should therefore be coordinated globally as far as possible. The financial regulatory reforms introduced in recent years have done much to enhance the stability of the financial markets and market participants. The more stringent capital and liquidity requirements, in particular, are sensible safety nets in a complex environment. It remains reasonable that the G20 and the FSB continue with this coordination. However, we warn against overtightening the regulatory screws at this juncture by introducing further requirements and call for a thorough review of existing regulation.
With regards to content, we would like to note our core findings and remarks, that we understand merit the utmost attention so to ensure a smooth review of regulatory impact and shape the fine-tunings to come.
• SMEs are the main components of the corporate landscape in Europe. Bank loans are the most important and demanded form of SME financing in Europe. The financing mix of SMEs in the EU differs quite substantially from other jurisdictions around the globe and entails varied specificities.
• The impact of regulatory measures in such an SME-filled environment need to be carefully calibrated as to avoid unintended consequences. Regulatory measures taken at European level can be strongly felt. Continued regulatory support to bank financing of the economy is critical to ensure proper financial intermediation and risk management.
• The new regulatory reform might put SME exposures at a disadvantage with regard to other alternative uses of capital in the banking sector. This might be an unintended consequence of the vast regulatory overhaul that has put the banking sector worldwide on a much stronger footing overall (higher need for collateral, long-term loans becoming more difficult etc.).
• These negatives effects have not yet really been perceptible (even if some hints are sprouting). This comes attached to the improvement of the economic situation in recent years/after the crisis, fostered by the unconventional monetary policy by the ECB (phase of zero interest rates), and its asset-purchase programme. However, the Basel III package has not yet been in place over a complete business cycle. In addition to that, modern economies are undergoing structural change and have a strong need for innovation and its financing. The capital requirements need to take into account that the economy need banks that are able to fulfil these financing needs. In addition, SME-focused policies at EU level, in the shape of direct public support or additional regulations on alternative financing methods have occupied the place of banks. However, direct capital market access is unlikely to be able to replace the financing of [average] SMEs. Direct market access is usually a possibility for larger corporates only.
• Policies affecting banks more concretely, have taken very specific shapes at European level, which we reflect on our analysis below: tackling the impact of Basel III and the its finalisation (Basel IV), securitisation, the SME Supporting Factor, the critical issue of NPLs in Europe and changes in its management due to regulation, IFRS 9 and the heightened regulatory scrutiny.
• Regarding other reforms impacting SMEs, as mentioned above, we mention the focus on European topics (in connection with the Capital Markets Union project), dealing with the European SME definition, SME growth markets, regulation of crowdfunding, among others. Specific substitution effects on specific business lines and also with respect to public finance and the different financing mix in innovative companies / new entrepreneurs.
• Finally, we shortly highlight positive voluntary initiatives from the banking to improve the information possibilities of SMEs and their ability to reach the financing they need.
We look forward to discussing these issues more in depth and engaging with you in the more focused consultation to be launched in June to develop more arguments and clarifications.
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]]>BRUSSELS, 17 December 2020 – The European Banking Federation notes the publication this week by the European Banking Authority (EBA) of its updated assessment[1] of the impact of the forthcoming Basel III agreement implementation on the capital requirements of Europe’s banks.
The EBA study shows that the impact on banks’ balance sheets remains very significant (+ 18.5%, and even more for Europe’s largest banks which account for most of the region’s assets: + 22.4%). The assessment still amounts to a capital shortfall of between €33 billion and €52.2 billion, most of it in large banks. Important is to note that the EBA’s analysis does not consider any detailed quantification of the financial impact from the Covid-19 pandemic, although its simulations suggest further material increases in capital shortfalls.
Contrary to the study[2] published by Copenhagen Economics, the EBA study still does not take into account the current capital ratios of banks. Banks indeed typically operate with capital buffers, e.g., as capital ratios fluctuate as part of the daily business and due to expectations from supervisors as well as investors. The current crisis has laid bare the importance of the management buffers. Thanks to the management buffer European banks have been able to withstand a major economic shock and keep up the level of lending. Therefore, the EBF reiterates that the EBA should use as main reference the sheer amount of capital needed to restore the current capital ratios.
It appears therefore essential that the European Commission implement the Basel IV framework at the European level with no significant adverse impact on any jurisdiction while respecting the international level playing field in banking and taking into consideration the European specificities.
The EBF believes that appropriate implementation of Basel IV is even more important in the context of the recovery from the COVID-19 crisis for banks to be able to continue providing
the very much needed financing for corporates, SMEs, and households. Doing it diffidently would put at risk the chance of a sustainable recovery in Europe.
To mitigate this adverse impact, the EBF has identified a number of concrete implementational options to make the package more suited to the European specificities, including the possibility to implement the output floor as a separate capital requirement where only internationally agreed capital buffers are applied (the so-called parallel stack approach), solutions to avoid penalising unrated corporates which form the vast majority of companies in Europe, a cap to the operational risk requirement in line with other jurisdictions, as well as maintaining the options already enacted in European legislation (CVA, SME supporting factor, etc.).
[1] https://eba.europa.eu/sites/default/documents/files/document_library/Publications/Reports/2020/961423/Basel%20III%20reforms%20-%202019Q4%20update%20and%20Covid%20impact.pdf
[2] https://www.copenhageneconomics.com/publications/publication/eu-implementation-of-the-final-basel-iii-framework#:~:text=In%20December%202017%2C%20the%20Basel,for%20different%20types%20of%20portfolios.
MEDIA CONTACT:
Ruta Barthet, Senior Communications and Media Officer
r.barthet@ebf.eu, +32 492 46 73 04
x
Raymond Frenken, Director of Communications
r.frenken@ebf.eu +32 2 508 3732
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. Website: www.ebf.eu
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]]>BRUSSELS, 14 June 2017 – Responding to the EU consultation on financial technology, also known as FinTech, the European Banking Federation is submitting a response which underlines its desire to see the creation of a customer-centric and inclusive ecosystem in which all actors, ranging from small start-ups to established multinational banks, are committed to serving clients with innovative financial services.
The EBF applauds the European Commission for initiating this consultation and for creating its FinTech taskforce. The taskforce serves not only a bridge between policy makers and the industry but also as an essential horizontal connection between policy makers in financial regulation and the digital agenda in the EU.
Says Wim Mijs, Chief Executive Officer of the EBF:
“There is no denying that financial technology is the DNA of our industry. Banks actively embrace FinTech to serve clients with new products and services, and it’s great to see how fresh competition helps us keep our focus. If we as Europeans really want to play a role in FinTech globally we need to create room for innovative financial services in a flourishing Digital Single Market. As I’ve said before: we need action at an overclock speed please. This consultation marks a key moment. It’s now time to overclock Europe.”
In its response to the EU consultation, the EBF emphasises the following:
Media contact:
Raymond Frenken, Head of Communications, +32 2 508 37 32, r.frenken@ebf.eu
Nahuel Mercedes, Communications Officer, +32 2 508 37 48, n.mercedes@ebf.eu
About the EBF:
The European Banking Federation is the voice of the European banking sector, uniting 32 national banking associations in Europe that together represent some 4,500 banks – large and small, wholesale and retail, local and international – employing about 2.1 million people. EBF members represent banks that make available loans to the European economy in excess of €20 trillion and that securely handle more than 400 million payment transactions per day. Launched in 1960, the EBF is committed to creating a single market for financial services in the European Union and to supporting policies that foster economic growth.
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
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
2 June 2017: Banks support ecosystem of interoperable APIs in EU: EBF underlines importance of privacy and security under PSD2
23 May 2017: Data Protection Impact Assessment: EBF comments on Article 29 Working Party guidelines
16 May 2017: EBF asks Commission to support ban on screen scraping
10 May 2017: Digital Single Market: EBF supports innovative, competitive strategy giving confidence for consumers and businesses
26 April 2017: EBF Key messages on European Commission’s Consultation on Building the European Data Economy
14 November 2016: Innovate. Collaborate. Deploy: the EBF vision for banking in the Digital Single Market
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]]>The European Banking Federation, responding to the European Commission’s Inception Impact assessment for a legislative proposal for an EU framework on crowd and peer to peer finance, sees this plan as a good starting point considering that crowdfunding has the potential to be a key source of financing for SMEs over the long term.
The combination of crowd-based activities, social media and automated matching platforms that apply innovative technology may significantly change the way consumer/SME credit is contracted. It also changes the way equity investment flows into start-ups, scale-ups and SMEs, as they offer new gateways to finance for individuals and small companies facing difficulties to tap the traditional banking channels.
We believe it would be desirable to have a consistent EU wide regulatory framework for consumer protection and considering/reviewing whether specific categories of crowdfunding service providers are in fact subject to existing financial regulation appears prudent actions to a positive way forward.
Therefore, the EBF would support the Policy Option 3 indicated in the Inception Impact Assessment. This option would define a comprehensive EU framework by introducing a specific license for crowdfunding with passporting rights will contribute the most to: (i) reduce existing divergences across Member States, and (ii) achieve a level playing field in which the same activity is subject to the same regulation. Options 1 and 2 would not suffice to address the issues that are correctly identified by the European Commission: (i) these would not contribute to crowdfunding reaching a
cross-border scale and (ii) would not help in providing an effective risk management framework that ensures sector integrity and trust. Option 4 could facilitate the scale-up of crowdfunding platforms across countries, but would not go as far as option 3 in achieving a level playing field across borders, and could lead to the prevalence of different standards in terms of investor and consumer
protection in those platforms that choose to conduct only national business.
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]]>The EBF supports the initiative of the European Commission to consult on how the definition of micro, small and medium-sized enterprises (SMEs) could be improved to keep being fit for purpose. We fully agree on the importance of SMEs as the backbone of the EU economy and as key motors of new investment and job creation, this is why having an updated definition of these entities is clearly a step into the right direction. As financing the economy, and in a wider sense, financing growth, is a key central strategic priority for the EBF, we fully support an initiative that seeks to review the current definition to ensure that it remains fit for purpose and meets its objectives in the current economic environment.
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]]>BRUSSELS, 14 September 2020 – The European Banking Federation has responded to the European Commission consultation on Research amending delegated directive (EU) 2017/593.
Find the EBF response to this consultation by clicking the ‘full document’ link below:
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]]>BRUSSELS, 27 May 2020 – SMEunited and the European Banking Federation have agreed on joint recommendations for improving the scope and effectiveness of the current funding flows to SMEs in need.
SMEunited and the EBF represent the Crafts and SMEs and the banks – large and small, wholesale and retail, local and international – in Europe, respectively. The two associations are joined by their common interest in ensuring an adequate, speedy, smooth credit flow and provision of other critical services to Europe’s SMEs at a time of extraordinary challenges for small companies in Europe. SMEunited and EBF have come together to make recommendations for improving the scope and effectiveness of the current funding flows to SMEs in need.
It is important to stress that this current statement is focused on the rescue/stabilisation phase of the crisis, rather than the recovery, which will involve its own set of challenges and priorities.
Both organisations agreed in the importance of an adequate, speedy, smooth credit flow and provision of other critical services to Europe’s SMEs at a time of extraordinary challenges for small companies in Europe. SMEunited and EBF believe that several actions could, and should be taken to coordinate practical solutions and best practices that can improve the lending processes and the terms of funding available to SMEs.
In this statement, they argue for an improved dialogue for SME and Banking Associations at a national level to identify specific problems. They need also to get in contact with the providers of public schemes to ensure that the support reaches out to SMEs as fast as possible and without unnecessary burdens.
Finally, the statement has been published ahead of a Roundtable meeting Executive Vice President Valdis Dombrovskis has organised for the 28 May to discuss with the financial sector, business and consumer organisation the situation as regards access to finance in times of COVID-19.
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]]>Publication date: 19 March 2020
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European Banking and SME Organisations move forward an industry-wide dialogue on access to credit
Dear Executive Vice-President Dombrovskis,
First of all, we would like to express our appreciation and gratitude to you for having engaged with the business and banking industries upon the signature of the ‘High-level Principles on Feedback Given by Banks on Declined SME Credit Applications’ (simply: the SME Feedback Principles, or the Principles), and for attending the presentation and signing ceremony in June 2017. As you are aware, the Principles are aimed at improving the dialogue between a company seeking finance and a bank through the provision of better information by both in relation to financing requests that cannot be accommodated in full.
Upon signature, it was agreed that members of the EU banking associations would encourage discussions at the national level and that they would enter into a structured dialogue with their SMEs representative counterparties while promoting the agreed Principles at the European level. In addition, the signatories agreed to undertake a joint stock-taking exercise two years after the approval of the Principles.
Today, following a productive and cooperative discussion among signatories, we are pleased to inform you that the stock-taking exercise on the status of implementation of the Principles was successfully concluded in 2019, demonstrating positive and encouraging outcomes as set out in the attached appendix.
The cross-reference of data available has shown that at a national level, banking and SME associations have, in the vast majority of cases, established a structured dialogue on the expectations of both sides from the SME Feedback process, allowing for different initiatives aimed at implementing the Principles or to facilitate the discussions on SME access to finance in the different jurisdictions.
As a matter of fact, in recognition of the substantial value generated by the comprehensive dialogue among our associations throughout this exercise, we intend to broaden the ongoing industry-led discussions by continuing our exchange of information in the form of a series of regular coordination meetings {e.g. once or twice a year, as deemed useful) among banks and SMEs representatives {on an open and inclusive basis) to discuss the wider spectrum of issues related to SME access to finance that pertain to the EU level. Such discussions will complement those at the national level, which we will continue to encourage in the spirit of the agreed Principles.
We will update the European Commission on the outcomes of our discussions as well as on the broader issues relating to SME access to finance.
Yours Sincerely,
Daniel Bouzas, d.bouzas@ebf.eu
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]]>1) Modify the scope in a proportionate way, to add certain categories of companies not currently covered by the NFRD as follows
Inclusion of SMEs, whose lack of data poses a problem for banks should be considered based on a minimum and possibly simplified set of information that could be provided by SMEs in a structured manner consistent with EU standards, given due considerations to proportionality and materiality.
2) Specify in more detail what non-financial information companies should report, namely a common minimum set of key performance indicators; these KPIs must be aligned with the list of Taxonomy-compliant activities and products they produce.
Denisa Avermaete, d.avermaete@ebf.eu
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