Position papers

  • Consultation Supervisory handbook on the validation of rating systems under the Internal Ratings Based approach 

    Banking supervision 24 October 2022

    By means of a manual, the EBA wants to create transparency with regard to supervisory expectations in relation to the validation of IRBA rating systems and in this way provide a reliable and uniform framework for banks. In principle, this is to be welcomed. However, care should be taken that the proposed regulations do not contradict or go beyond existing supervisory requirements.

  • EuGBS - EAPB comments in light of trilogue negotiations

    Capital markets, Sustainable finance 17 October 2022

    EAPB statement on the ongoing EuGBS inter-institutional negotiations. EAPB members highlight the importance of the voluntary nature of this new standard, as well as tailored rules for portfolio approach issuers.

  • Consultation on review of the guidelines on MIFID II product governance requirements

    Capital markets 7 October 2022

    EAPB welcomes clarifications to the existing guidance. However, we have a few reservations with respect to the proposed clarifications in paragraphs 13-23. The requirement to consider qualitative factors in addition to quantitative factors (par. 14) for all financial instruments and in every case is too far-reaching. It should be possible to use exclusively qualitative or exclusively quantitative factors

  • EAPB answer to the call for feedback on the Platform for Sustainable Finance's report on minimum safeguards

    Sustainable finance 14 September 2022

    This call for feedback is part of ongoing work by the Platform on Sustainable Finance, which was set up by the Commission to provide advice on the further development of the EU taxonomy framework. This feedback process is not an official Commission consultation. The draft report produced by the Platform is not an official Commission document. Nothing in this feedback process commits the Commission nor does it preclude any policy outcomes.

  • Consultation Paper: Draft Regulatory Technical Standards on the identification of a group of connected clients under Article 4 paragraph 1 number 39 of Regulation (EU) No 575/2013

    Banking supervision 29 August 2022

    We appreciate the example provided. The example seems to be targeted to SSPEs, we would appreciate if it could be clarified that the example holds for SPE/SPV in general. Moreover, it would be helpful if additional examples would be provided for structures (other than SPV/SPE) where the risk is segregated but control relationship exists.

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