Position papers

  • Position paper 31/2017 - EAPB Position Paper on BRRD / SRMR Review Proposals

    Banking supervision 15 November 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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  • Position paper 29/2017 - EAPB Position Paper on Euro-Clearing

    Capital markets 10 November 2017

    The European Association of Public Banks (EAPB) welcomes the timely proposal for the reform of the Euro-Clearing rules under the EMIR Regulation. We consider this dossier highly important due to the upcoming departure of the United Kingdom from the European Union, with the threat of having the UK cut off the Single Market without any transition deal for financial services. While it is in the interest of the European economy that the clearing services remain in one place in London, the equivalence regime which will be applicable for the London-based services must warrant legal certainty and predictability for businesses. We also call on the legislators to take into account the protection of existing contracts.

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  • Position paper 23/2017 - EAPB Position Paper on EMIR Review (REFIT)

    Capital markets 10 November 2017

    The European Association of Public Banks (EAPB) welcomes the proposal of the European Commission for a regulation amending the European Market Infrastructure Regulation (EMIR REFIT). We support the most of the presented amendments, such as deletion of the backloading and frontloading requirements as well as the possibility to suspend the clearing obligation in situations other than resolution. Nevertheless, we call for clarification of the provision concerning the non-discriminatory access to clearing services. Moreover, we stress that the discrepancy in the introduction of the single-sided reporting should be corrected by the legislators, in order to achieve the intended simplification for the market participants.

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  • Position paper 30/2017 - AECM, EAPB, ELTI & NEFI Comments on the Interim Evaluation of the Programme for the Competitiveness of Enterprises and Small and Medium-sized Enterprises (COSME) (2014-2020)

    Development, State aid 7 November 2017

    The European Association of Guarantee Institutions (AECM), the European Association of Public Banks (EAPB), the European Association of Long-Term Investors (ELTI) and the Network of European Financial Institutions for Small and Medium Sized Enterprises (NEFI) warmly thank the European Commission for the possibility to provide feedback on the interim evaluation of the programme for the competitiveness of enterprises and small and medium-sized enterprises (COSME) (2014-2020) focussing on the activities of the period of 2014 to 2016.

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  • Position paper 28/2017 - EAPB’s position on the BCBS consultation on the simplified alternative to standardised approach to market risk capital requirements

    Banking supervision 3 October 2017

    The EAPB would like to provide the Basel Committee on Banking Supervision with the following specific comments

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