Position papers

  • EAPB response to targeted review of the General Block Exemption Regulation (State aid): extension to national funds combined with certain Union programmes

    Development, State aid 23 September 2019

    The European Association of Public Banks, EAPB, welcomes the possibility to provide feedback on the Draft Commission Regulation amending Regulation (EU) No 651/2014 declaring certain categories of aid compatible with the internal market in application of Articles 107 and 108 of the Treaty (GBER) .

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  • Joint position paper on InvestEU by EAPB AECM ELTI NEFI

    Development, State aid 22 September 2019

    AECM, EAPB, ELTI, NEFI and their members, as potential Implementing Partners (IP) and Financial Intermediaries for InvestEU, welcome and highly value the transparent and co-operative approach adopted by the European Commission in the development of the new InvestEU programme.

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  • EAPB response to public consultation on Draft Commission Notice on the recovery of unlawful and incompatible State aid

    Development, State aid 25 April 2019

    The European Association of Public Banks, EAPB, welcomes the possibility to provide feedback on the Draft Commission Notice on the recovery of unlawful and incompatible State aid. As National and Regional Promotional Banks and institutions (NPB) EAPB members perform a public mission of fostering economic development and social cohesion. They act on the basis of a public mandate -defined by lawand support their competent authorities’ socio-political objectives. They thus often also play a key role in granting State aid.

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  • AECM EAPB ELTI NEFI SME united Invest EU position paper

    Development, State aid 15 February 2019

    In this paper, AECM, EAPB, ELTI, NEFI and SMEunited (in the following “the Stakeholders”) would like to contribute to the ongoing legislative procedure regarding the proposal for a regulation establishing the InvestEU Programme and more precisely to the SME-related aspects of the InvestEU Fund.

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  • EBIC answer to EC questionnaire on FIU cooperation and AML/CFT supervision at EU level

    Financial crime 20 December 2018

    We welcome the opportunity to comment on the European Commission proposals and ideas on improving FIU cooperation and strengthening Anti-Money Laundering and Combatting Financing of Terrorism (AML/CFT) supervision at EU-level. Acknowledging the seriousness of the current money laundering cases we believe that these cases are based – insofar as this can be judged – not on regulatory, but on enforcement deficiencies of the competent authorities.

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