Position papers

  • Position paper 33/2017 - EAPB Position Paper on ESA Review Proposal

    Banking supervision 13 December 2017

    The EAPB generally welcomes the overhaul of the legislation on the European Supervisory Authorities (ESAs). It believes that a review of the ESAs can enable them to more strongly promote supervisory convergence, thereby contributing to more legal certainty and a level playing field.

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  • Position paper 32/2017 - Joint AECM/EAPB/NEFI Position Paper on the Future of EU Finances

    Development, State aid 27 November 2017

    As the main intermediaries for EU Structural Funds and other EU financial Instruments (COSME, InnovFin etc.) the member institutions of AECM, EAPB and NEFI are key players in addressing economic and social challenges in the Member States and their regions. By providing amongst others greater leverage, geographical coverage, as well as specific market knowledge, Promotional Financial Intermediaries bring crucial added value to the success of the EU economic policies. Based on the comprehensive experience of our member institutions at national, regional and local level, we are pleased to share our thoughts in the debate on the future of EU finances and on how Promotional Financial Intermediaries can be further encouraged to participate in EU programmes.

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  • 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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