Generally the EAPB agrees with the prioritisation of EBA and welcome the approach to discuss important technical aspects of the SA-CCR and FRTB at an early stage with the industry. However, we believe that the definition of the revised trading book boundary should be addressed at an earlier stage too. In order to give guidance on implementation and investment decisions, especially the understanding of exceptional circumstances and reclassification has to be given early to allow for alignment of risk and accounting departments. Additionally, the boundary definition will have impact on trading desk structure.Download
The EAPB submits this joint answer to the public consultation on the future of of EU investment policies in the next programming period. Our members are ready to participate in the implementation of the future EU financial instruments and funds and provide their experience from the current Multiannual Financial Framework to suggest some improvements, including cutting the administrative burden and alligning rules governing different EU programmes. To maximize the results of the EU economic policies, there should only be a limited number of sufficiently equipped funds that will provide financing for broadly defined policy areas - e.g. SME financing, infrastructure, or innovation. The European Union should actively seek cooperation with national and regional promotional banks to always create an additional leverage of joint investments and risk-sharing to the benefit of the real economy.Download
The EAPB submitted its joint reply to the public consultation on the future of the EU Cohesion Policy. Our members support a continuation of this policy and recommend cutting the administrative burden and simplifying the State Aid rules. Moreover, we underline that the legislative framework for the post-2020 Cohesion Policy must be adopted before the beginning of the next programming period in order to avoid delays in implementation.
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.Download
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.Download