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
In general, EAPB supports the intention of the "Action Plan" to reduce non-performing loans (NPLs). In order to ensure stability in the banking sector and to move towards the completion of the banking union, a reduction of NPLs seems necessary. Therefore, ensuring that financial institutions make sufficient provisions for loans that are non-performing is of importance. The Commission’s proposal of dealing with NPLs then is to create minimum coverage levels for newly originated loans that become non-performing. These will act as a statutory prudential backstop. For the EAPB however, the creation of a minimum level that is fixed for all institutions, independent of risk and independent of the amount of NPLs seems excessive.Download
The European Association of Public Banks, EAPB, welcomes the possibility to provide feedback on the possible revision of the EU SME Definition as provided in the Recommendation 2003/361/EC. Generally EAPB believes that the small and medium-sized enterprises (SME) Definition has proven its worth in identifying those enterprises which are confronted with market failures particularly in the area of access to finance. As National and Regional Promotional Banks and institutions (NPB) EAPB members perform a public mission of fostering economic development, especially by contributing to SMEs growth. Thus, it supports any initiative from the European Commission to create favorable framework conditions for SMEs. SMEs form the backbone of the European economy. They are indispensable for growth, employment and innovation in the EU. Economies with a
stable medium-sized base are evidently developing better.
In the aftermath of the financial crisis, regulation has become not only more intensive and extensive, but also more complex. Standards of the Basel committee are intended for, and tailored to, large, complex, and internationally active financial
institutions. As a result, the rules themselves have become large and extremely complex, and the “Finalization of Basel III” (Basel IV) is no exception.
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