The EAPB represents a numbers of regional and national promotional banks (NPBIs) that are potential implementing partners of the European Union under the InvestEU proposal. The EAPB shares the view of the Draft Opinion that the future role of the EIB Group, as the treaty-based EU bank, should be more clearly defined and that its investment activities should continue, including the successful EIF programmes COSME and Horizon 2020. We
also believe that the governance structure as proposed by the Draft Opinion ensures a better political balance to the InvestEU management, brings in more banking expertise to the decision-making process, and cuts the high costs of delegating experts for implementing partners.
Due to the nature of their business models, public banks have often been among the pioneers of the sustainable finance market. The public promotional banks are frequent and large issuers of green bonds all across Europe and have considerable experience in providing their intelligence to other market players. Against this background, the EAPB welcomes the set of proposals aiming to enhance the role of financial sector in achieving a sustainable economic growth. We believe that the proposals represent an important step towards reaching the climate goals of the Paris Agreement.Download
With this Position Paper, the EAPB would like to briefly comment on the Draft Report on the proposal for the Regulation on disclosures relating to sustainable investments and sustainability risks 2018/0179(COD) tabled by Mr. Paul Tang MEP on 2 August 2018. In principle we welcome that the ESG criteria should apply to all market participants. However, various new disclosure standards and requirements, as proposed, would only create additional administrative burden and imply significantly higher costs without benefits to customers, market participants, or tax payers. Moreover, it does not seem that the Draft Report and the legislative proposal take into account the entire regulatory framework already in place for financial institutions, such as MiFID II, PRIIPs, etc.Download
The EAPB welcomes the timely proposal for the InvestEU programme comprising a single fund for all EU-level financial instruments in the Multiannual Financial Framework (MFF) 2021-27 as well as the advisory and technical support. This proposal largely addresses some of the shortcomings occurring in the current programming period and sets out an ambitious investment plan for the next MFF. From the perspective of public promotional banks, the elimination of the existing fragmentation of EU-level financial instruments and funding schemes is the right approach. Filing a single application and following a single rulebook will allow financial intermediaries across the whole European Union to implement the entirety of this large financial envelope. This will facilitate channeling of the European investments into the real economy and boost the efficiency of the EU economic policies.Download
Generally speaking, the European Association of Public Banks (EAPB) welcomes the Commission’s proposed amendments to the Cross-Border Payments Regulation, which aim to strengthen fairness and increase consumer transparency. In particular, we share the opinion that transparency may be a decisive parameter in a functioning market. However, we believe that some aspects of this proposed Regulation may have substantial impact on the EU banking sector and we would therefore like to raise the following specific comments.Download
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