Position papers

  • 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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  • EAPB and AECM joint statement to the legislative process of the Regulation proposal establishing the InvestEU Programme 2021-27

    Development, State aid 5 December 2018

    With this paper the European Association of Public Banks (EAPB) and the European Association of Guarantee Institutions (AECM) would like to express their views on the newest developments in the negotiations concerning the regulation proposal for the InvestEU Programme 2021-27.

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  • EAPB Comments on the amendments of the European Parliament to the ECON/BUDG Draft Report 2018/0229 on the establishment of the InvestEU Programme

    27 November 2018

    The European Association of Public Banks (EAPB) is presenting this paper commenting on the amendments tabled by Members of European Parliament to the Draft Report to the regulation proposal establishing the InvestEU Programme in the MFF 2021-27. Since some 800 amendments were tabled to the ECON & BUDG Secretariat, the EAPB is offering short, summarizing comments from the perspective of national and regional promotional banks or institutions (NPBIs) foreseen to become the implementing partners of this programme.

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  • EAPB Comments on the ECON/BUDG Draft Report 2018/0229 on the establishment of the InvestEU Programme

    Development, State aid 1 November 2018

    The EAPB welcomes the deletion of the Project Team as a key step in making the governance structure more efficient. In addition, we would like to draw the attention of the European Parliament to the confusing composition of the amendments modifying the governance structure. Not only is it unclear what is the envisaged final wording of the Regulation but also readers also entirely miss the actual mission and tasks of the Steering Board and the Advisory Board, as well as the integration of the Risk Management in the overall governance structure.

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