Position papers

  • EAPB Draft Position Paper on BRRD / SRMR Review Proposals

    Banking supervision 3 April 2017

    On 23 November 2016, the European Commission published a set of proposals on the current legislative framework for the EU Banking Union. The proposals constitute the most substantial amendments to the existing provisions since the establishment of the post-crisis framework and make important changes to the Bank Recovery and Resolution Directive (BRRD) and the Single Resolution Mechanism Regulation (SRMR).

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  • Specific comments on CRR Review Proposals

    Banking supervision 3 April 2017

    The European Commission’s proposal foresees a change in the criteria for AT1- and T2-capital instruments by stipulating that these instruments must be directly issued by the respective institution. This requirement is obviously intended to align the criteria for own funds instruments with the criteria for eligible liabilities. EAPB opposes the introduction of this criterion as it goes beyond the BCBS’ standards and does not create any prudential benefit as indirectly issued capital instruments are also immediately available for loss absorption. Therefore, no changes should be made in articles 52 and 63.

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  • Specific comments on CRD Review Proposals

    Banking supervision 3 April 2017

    With regards to the general scope of the CRD, article 2 (5a) lays down objective criteria according to which the Commission may establish an exemption from the scope of the CRR/CRD for ‘public development-type’ institutions. EAPB welcomes this proposal but would want to emphasize that it has to be without prejudice to already existing exemptions in CRD article 2 (5) or differentiated treatment of promotional banks in some of the provisions of the CRR and without prejudice to the powers of the co-legislators to add institutions to the list in article 2 (5) under the ordinary legislative procedure.

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  • EAPB comments on the European Commission’s second draft for a Regulation amending the General Block Exemption Regulation on state aid measures

    State aid 2 December 2016

    The EAPB welcomes the opportunity to comment on the second draft regulation amending the General Block Exemption Regulation (GBER) published on 7 March 2016. Unfortunately none of our key demands expressed in our position paper from 13 October 2016 following the first consultation have been considered. We therefore refer to our previous position paper for further consideration:

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  • EAPB Position Paper on the extension of the Investment Plan for Europe

    30 November 2016

    In light of the future development concerning the Investment Plan for Europe (IPE) the European Association of Public Banks (EAPB) aims to explain its members‘ involvement in the implementation of the IPE. The aim is also to set out the priorities and concerns of the EAPB members in the context of the upcoming legislative process regarding the proposal “European Fund for Strategic Investments: extension of duration; technical enhancements for the Fund and the European Investment Advisory Hub” (COM(2016) 597) of 14 September 2016.

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