FOR IMMEDIATE RELEASE
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Call for the co-legislators to assess the Retail Investment Strategy in light of the Commission’s competitiveness objectives
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Brussels, 28 November 2024 – The undersigned associations welcome the new European Commission’s objectives to boost the EU’s competitiveness, focus on the enforcement of existing legislation and simplify regulatory frameworks. We appreciate that this was also echoed by the Commissioner-Designate Maria Luis Albuquerque during her confirmation hearing in the European Parliament.
In light of this and the need to urgently advance a Savings and Investments Union, it is essential to subject the Retail Investment Strategy (RIS) to a “competitiveness check”. As it currently stands, the RIS will not achieve its initial goal of increasing retail participation in European capital markets.
Indeed, the RIS adds further complexity and bureaucracy to the already heavily regulated frameworks that govern the distribution of investment and insurance-based investment products (IBIPs), with impacts for both firms and retail investors. This approach contradicts the new Commission’s commitments to reducing red tape for market participants, fostering a simpler regulatory environment and strengthening the attractiveness of EU financial markets.
We have hope that EU policymakers can use the upcoming trilogue negotiations to refocus the RIS on what matters: enabling citizens to invest in the capital market without imposing excessive burdens on market participants. For this to happen, policymakers must, at a bare minimum, focus on:
- Simplification for firms and retail investors. Overly complex and overlapping rules risk stifling retail investor engagement and increasing firms’ operational costs, which are ultimately borne by The RIS, as currently proposed, would significantly increase the reporting burden and record-keeping requirements, adding layers of bureaucracy and red tape for market participants. Additionally, the introduction of numerous Level 2 and 3 empowerments would create further uncertainty and complexity for companies. The RIS should aim to streamline regulations and avoid imposing new, disproportionate compliance requirements that create obstacles for both investors and the market.
- Streamlined sales processes for retail investors. An easy, affordable, and simplified investment journey will be vital to attracting more retail investors. Unfortunately, the current RIS proposals would make the investment process longer and more burdensome, adding conditions, tests and disclosure obligations. For instance, the advice process for purchasing products can extend to over two hours for certain products, discouraging savers from investing or nudging them towards less regulated platforms and products. The RIS should strive to reduce these barriers and ensure that investors can access European-regulated products in a leaner way.
- Reduction of information overload. Transparency is important for empowering investors to make informed decisions. At the same time, the RIS currently imposes excessive and overly detailed cost disclosures and warning obligations which could overwhelm retail investors and could make investing less appealing. The RIS should improve and focus on meaningful and relevant disclosures. Emphasising key product benefits, such as financial guarantees, ESG characteristics and other qualitative features that drive consumer investment decisions, will encourage greater participation in the EU financial markets.
These steps are just a starting point for the RIS to foster a regulatory framework benefiting both retail investors and the wider EU economy. In this spirit, the financial industry also appreciates the Commission’s strong commitment to deploying the Savings and Investments Union and driving retail investment across the EU, while working with Member States on key actions necessary to strengthen our capital markets, such as unlocking the potential of private and occupational pensions, targeted tax incentives and financial and insurance literacy.
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For more information please contact:
Jacopo Borgognone
Senior Advisor, Financial Markets 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 federation 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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]]>EBF POSITION PAPER
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Recommendations to Optimize EU Financial Instruments/Budgetary Guarantees and EU Promotional Policies
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BRUSSELS, November 2024 – The European Banking Federation (EBF) has published a position paper calling for improvements to EU financial instruments and budgetary guarantees to better support the green and digital transitions of the European economy.
Massive amounts of private capital are needed to finance the European economy and its green and digital transitions. Some of these investments will only happen thanks to well-designed financial instruments and budgetary guarantees, especially EU-level guarantees for loans, loan portfolios and securitizations, to mitigate risks and “crowd in” private capital.
European private sector banks have a longstanding engagement in partnering with public sector institutions to finance the desired underlying economic activities. As their pan-European representative, the EBF has come forward with a set of recommendations to improve the functioning of financial instruments and budgetary guarantees so they can be more targeted, standardized, simple, digital and marketable.
The EBF is committed to continued cooperation with the EU and national authorities in the process of streamlining and optimizing these funds.
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For more information please contact:
Burçak Inel
Director of Financing Sustainable Growth, b.inel@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 federation 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 Paper on the Recommendations to Optimize EU Financial Instruments/Budgetary Guarantees and EU Promotional Policies appeared first on EBF.
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Next Steps for Europe’s T+1 Transition
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BRUSSELS, 15th November 2024 – The EBF calls for a EU – T+1 implementation roadmap to be completed in the coming months.
The European Banking Federation (EBF) has long supported efforts to enhance the efficiency of the EU post-trade ecosystem to promote the attractiveness and competitiveness of EU capital markets. Against this background, the EBF is fully supportive of a successful move to T+1 in the EU and recognises the potential benefits in terms of efficiency gains and risk reduction. Considering the unique EU market structure and operational model, it is clear that a move to T+1 in the EU would be a complex, multi-year undertaking. Such transition, therefore, will demand the highest level of commitment and collaboration from all industry stakeholders and jurisdictional government bodies to ensure that any undue risks are mitigated to the greatest extent possible to avoid undermining the existing efficiency, liquidity and functioning of EU securities markets.
The EBF considers that a successful move to T+1 in the EU should be seen as a collective interest of all EU member states and of all financial market stakeholders, with strong benefits for the European economy as a whole, and therefore requiring an equally strong and dedicated collective effort and coordination.
The transition to T+1 will have the potential to trigger a “virtuous circle” of coordinated market reforms (some of which long overdue) in the area of post-trade services, which will form the basis for more efficiency, more automation, more harmonization and integration of all activities, including settlements, corporate actions, tax reclaims and issuer-investor relationships. A successful transition to T+1 offers a unique opportunity, not to be missed, for significant progress across the industry and across all relevant stakeholders towards more efficient and integrated financial markets in Europe.
Against this background, a timely and comprehensive implementation roadmap leveraging the work completed by the EU T+1 Task Force, (including detailed analysis of all infrastructural, legal and operational changes to be completed ahead of the final migration date, as well as any associated project risks) will be critical to making the transition a success rather than a setback for the EU. This roadmap should clearly define ownership and sequencing of implementation milestones.
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For more information please contact:
Jacopo Borgognone
Senior Advisor, Financial Markets 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 federation 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 Paper on the Next Steps for Europe’s T+1 Transition appeared first on EBF.
]]>EBF and its Members Call for Balances Reforms to Boost Competitiveness and Investor Participation in EU Capital Markets
Brussels, 9 September 2024 – The European Banking Federation and its members are fully engaged in supporting the completion of a European Savings and Investments Union as called by Enrico Letta in his report published in April 2024. Developing EU capital markets will contribute not only to ensuring that the digital transformation and green transition of our economies are properly funded, but will secure the bedrock upon which EU competitiveness can be relaunched.
Currently, EU capital markets are losing competitiveness, as recently highlighted, among others, by the President of the Eurogroup, Pascal Donohoe and President of the European Commission, Ursula von der Leyen, who recalls in the EC Strategic Agenda 2024-2029 that the fragmentation of our financial markets sees ‘’EUR 300 billion of European families’ savings transferred to foreign markets every year”. Game-changing and ambitious reforms are therefore key. In this context, we fully support the aim of the European Commission to improve retail investors’ access and participation to capital markets through the Retail Investment Strategy (RIS) to ensure that more households benefit from the prosperity generated by EU companies and SMEs.
President von der Leyen also highlighted in the new EC Agenda the need to reduce red tape and administrative burden in order to improve EU competitiveness: “Each Commissioner will be tasked with focusing on reducing administrative burdens and simplifying implementation: less red tape and reporting, more trust, better enforcement, faster permitting.”
Against this background, we are concerned that the RIS, as proposed and currently negotiated, is bound to stay the opposite course, significantly increasing complexity, costs and administrative burden not just for firms, but -most importantly- for their clients, whose customer journey is heavily complexified.
The multiplication of checks, tests, overload of information and warnings ( i.e., proposals regarding the new inducement test, new best interest test and related clauses on the “unnecessary additional features”, as well as additional disclosure of costs and charges) will disincentivize savers from investing in financial markets and will lead them to prefer easily accessible unregulated products, such as crypto assets, a trend already seen occurring with new investors.
We believe that an effective investor protection should not lead to the superimposition of excessive requirements, but rather strike the right balance between clarity, flexibility, effectiveness, variety and freedom of choice. A key element of this is, in our opinion, the reinforcement of product governance via an adequate, workable Value For Money (“VFM”) framework. Provided that the rules are drafted in a calibrated way that allows for flexibility for investment firms, VFM could be an effective tool for managing potential conflicts and ensuring product-specific scrutiny of delivered value against the considerations of a full range of qualitative and quantitative features, costs and investment targets. Among the 3 proposals, the text proposed by the European Parliament seems to be the less prejudicial basis for this approach. However, some improvements still need to be made in upcoming interinstitutional dialogue, as the proposal in many ways remains unclear, is too complex, and risks leading to price regulation and impaired competitiveness.
This text is an opportunity to demonstrate the EU can rise to the challenge of competitiveness, reducing the number and superimposition of over-protection and anti-competitive rules, and at the same time reinforce a few well-targeted measures to strengthen and develop a domestic market of European players and investors, who are the key for financing the digital and green transitions.
The EBF continues to work in this direction with its members, drawing on their experience to identify and client-oriented solutions that may foster safe and informed access to capital markets.
For more information:
Jacopo Borgognone, Senior Policy Adviser – Financing Growth, j.borgognone@ebf.eu
Gabriel Daia, Head of Communications & Public Affairs, g.daia@ebf.eu
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.x
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The post EBF and its Members Call for Balanced Reforms to Boost Competitiveness and Investor Participation in EU Capital Markets appeared first on EBF.
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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.
The post EBF comments on the new EU Retail Investment Strategy appeared first on EBF.
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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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Listing Act – making public capital markets more attractive for EU companies and facilitating access to capital for SMEs
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BRUSSELS, 3rd May 2023 – The EBF fully supports the CMU objective of increasing participation by European companies to Capital Markets and welcomes the proposal to simplify the EU listing regulatory framework to facilitate access to funding in public markets.
- On the Prospectus Regulation: The focus of the Prospectus Regulation should be on simplifying and streamlining content and harmonizing practices, while leaving sufficient flexibility to issuers and intermediaries to assess appropriate content and length. Moreover, a limit to the length of the prospectus could be maintained as a general recommendation, rather than as a binding rule.
- On the Market Abuse Regulation: The EBF welcomes the changes proposed by the European Commission to alleviate the Market Abuse Regulation. Specifically with reference to the issue of what constitutes an “inside information”, to the clarification of the safe-harbor nature of the market sounding procedure and to the simplification of the insider list regime for all issuers. Welcomed changes also refer to the expansion of the scope of exempted transactions during the “close period” and to the simplification of reporting and disclosure f share buybacks.
- On the Directive on Multiple-Vote Share Structures: the EBF supports the establishment of an homogeneous regime at EU level to avoid unlevel playing field across the implementation of MVR schemes.
- On Investment Research: The EBF supports a complete review of the current research regime. To foster liquidity and support the provision of research services, the unbundling rule should be permanently eliminated, and joint payment of the research should be allowed with reference to all issuers, regardless market capitalization.
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For more information please contact:
Marta Morellato
Policy Advisor – Financing Sustainable Growth, 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 federation 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 Paper on the Listing Act Proposal 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
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]]>FROM THE EUROPEAN BANKING FEDERATION:
EBF Response: ESMA Call for Evidence on Market Characteristics for ESG Rating Providers in the EU
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BRUSSELS, 11 March 2022 – While ESG providers remain largely unregulated, their influence is expected to grow considerably. There are a series of underlying challenges, including discrepancies in ESG measurements and ongoing data quality problems. In particular:
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- Most users have difficulty understanding the underlying methodology for a specific ESG rating as ESG rating providers consider the methodologies proprietary information
- There is little coherence between methodologies amongst ESG rating providers, resulting in significantly diverging outcomes: the same company may be considered high risk, medium risk or low risk if rated by three different agencies
- ESG ratings do not always consider the impact and focus of an organization on the environment (double materiality) – hence there continues to be a gap between some investors’ expectations (e.g., of retail investors) and real impact
- A clear framework with consistent global principles and harmonized standards for ESG rating (EFRAG, IOSCO and International Sustainability Standards Board), which is currently lacking, would make it possible to have a clear and objective evaluation of financial market participants from an ESG perspective
You can read the EBF’s integral response to ESMA’s Call For Feedback on Market Characteristics for ESG Rating Providers in the EU below.
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For more information:
Denisa Avermaete, Senior Policy Adviser, Susatinable Finance d.avermaete@ebf.eu
Alexia Femia, Policy Adviser, Sustainable Finance a.femia@ebf.eu
Marta Morellato, Financing Sustainable Growth trainee 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
The post EBF Response: ESMA Call for Evidence on Market Characteristics for ESG Rating Providers in the EU appeared first on EBF.
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