The European Association of Public Banks, EAPB, welcomes the possibility to provide feedback on the possible revision of the EU SME Definition as provided in the Recommendation 2003/361/EC. Generally EAPB believes that the small and medium-sized enterprises (SME) Definition has proven its worth in identifying those enterprises which are confronted with market failures particularly in the area of access to finance. As National and Regional Promotional Banks and institutions (NPB) EAPB members perform a public mission of fostering economic development, especially by contributing to SMEs growth. Thus, it supports any initiative from the European Commission to create favorable framework conditions for SMEs. SMEs form the backbone of the European economy. They are indispensable for growth, employment and innovation in the EU. Economies with a
stable medium-sized base are evidently developing better.
In the aftermath of the financial crisis, regulation has become not only more intensive and extensive, but also more complex. Standards of the Basel committee are intended for, and tailored to, large, complex, and internationally active financial
institutions. As a result, the rules themselves have become large and extremely complex, and the “Finalization of Basel III” (Basel IV) is no exception.
EAPB position on draft Commission Regulation amending Regulation (EU) No 1408/2013 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid in the agriculture sector. The EAPB welcomes the opportunity to provide comments on the proposed draft amending regulation to the de minimis regulation for the agricultural sector. The EAPB highly appreciates that the Commission intends to increase the thresholds for aid in this key sector. Other proposals in the amendment, however, would make the granting of de-minimis aid very complex or even practically impossible for national and regional promotional banks.Download
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