Position papers

  • EBA Discussion Paper on proportionality assessment methodology - EAPB response to consultation

    Banking supervision 21 October 2021

    The EAPB has concerns that existing internal classifications together with CRR2 classifications will not achieve sufficient granularity to identify business models and/or activities that are disproportionately affected by specific pieces of regulation. See more detailed comments in the answers below.

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  • EAPB position on sixth extension and adaptation of the COVID TF

    State aid 13 October 2021

    We generally welcome this new extension of the Temporary Framework (TF) by another six months. This is because, on the one hand, of the liquidity and equity capital needs of many companies that continue to exist. On the other hand, in our view, the Temporary Framework also forms a good basis under State aid law for the first post-COVID period of economic recovery and transformation, both for equity financing and for loan financing to strengthen liquidity and investments. Therefore, the Temporary Framework should continue to be available in its full flexibility.

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  • European Commission consultation on the proposal for a Regulation on European green bonds

    Banking supervision 27 September 2021

    The EAPB welcomes the opportunity to comment on the Commission’s legislative proposal on European green bonds (EuGB). We welcome that the Commission has proposed a voluntary EuGB label rather than a binding one. However, the draft regulation falls short in several crucial respects that, if not addressed, would cause significant problems for both investors and issuers (bond-by-bond issuers as well as issuers who apply a portfolio approach, where a pool of green bonds finance a portfolio of eligible green assets).

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  • EAPB position on EU Taxonomy Goals 3-6_final

    Banking supervision, Capital markets, Development, State aid 27 September 2021

    The European Association of Public Banks (EAPB) welcomes the Sustainable Finance Platform's initiative to flank the EU Taxonomy on environmental criteria 1 and 2 (Climate Change Mitigation and Climate Change Adaptation) with guidance on how to include environmental goals 3 – 6 (sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control and protection and restoration of biodiversity and ecosystems).

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  • Joint associations letter re UK CCP recognition and equivalence

    Banking supervision, Capital markets 16 September 2021

    The Joint Associations ask the Commission to extend the equivalence decision for UK CCPs in order to prevent negative financial, commercial, operational and level playing field effects on EU counterparties and to enable continued access to global pools of liquidity after 30 June

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