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Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

Banking and financial services

This initiative intends to amend the Capital Requirements Regulation ((EU) No 575/2013) and will be part of a legislative package together with a proposal to amend the Capital Markets Directive (2013/36/EU). The package aims to implement the final elements of the internationally agreed prudential standards for credit institutions developed by the Basel Committee on Banking Supervision, also known as the “Basel III framework”.

Links

Public consultation

ID: 12015

Lobbying Activity

51 responses

Consultation response

WWF European Policy Programme, 23 Feb 2022

WWF welcomes the European Commission proposal to complete implementation of the Basel III agreement in the European Union, a helpful step to ensure better financial stability after the financial crisis. The timetable proposed by the Commission means that the EU will add another two years to the…

Consultation response

Airbus, 23 Feb 2022

Airbus welcomes the opportunity to comment on the proposed regulation, and would like to provide feedback on the considered strengthening of the applicable terms to trade finance instruments, particularly to technical guarantees. Airbus remains solidly rooted in the European banking system, and has…

Consultation response

Confederation of Swedish Enterprise, 21 Feb 2022

The Confederation of Swedish Enterprise welcome this opportunity to give feedback regarding the proposed amendment to Regulation (EU) No 575/2013 (the Capital Requirements Regulation or CRR) and the wider legislative package of which it is a part, known as Banking Package 2021. Please see the…

Consultation response

Fédération bancaire française, 18 Dec 2019

The European transposition of the Dec. 2017 Basel Accord is not merely an issue of banking supervision, but also one of the key issues in defending the sovereignty and competitiveness of the European economy. Banks have significantly increased their financial stability over the last decade (the…

European Banking Federation Opposes New Capital Deduction Rules

European Banking Federation, 20 Jan 2022

The EBF requests limiting deductions to eligible liabilities only, excluding own funds until a full impact assessment is conducted. They want adequate implementation time to avoid breaching MREL requirements. They argue the current proposal contradicts existing capital requirements and lacks proper impact assessment.
This would prevent intermediate parent entities from breaching requirements and maintain lending capacity.
Regulators lose stricter capital buffers designed to ensure bank resolvability during crises.

European Banking Federation warns Basel III impact understated

European Banking Federation, 17 Jan 2022

The federation argues the true capital impact is significantly higher than the Commission's 6-8% estimate, requesting the output floor be applied only at consolidated level and permanent solutions for unrated corporates and real estate exposures. They want numerous technical standards clearly framed to prevent scope creep beyond Basel Committee intent.
This would preserve their current capital buffers and lending capacity without raising additional capital.
Financial system stability loses if banks maintain lower capital buffers than intended by Basel standards.

Consultation response

UNIFE, 12 Apr 2022

UNIFE, the European Association of the Rail Supply Industry, shares its views and concerns on some concrete aspects of the new proposed Regulation, namely on the Credit Conversion Factor (CCF) for Technical Guarantees and Effective Maturity recognition for Trade Finance. UNIFE agrees with a wide…

Consultation response

Mouvement des Entreprises de France, 23 Feb 2022

In its Banking Package 2021, the Commission proposes a review of EU banking rules to finalise the implementation of the Basel III agreement in the EU. While we recognise the Commission’s efforts to take EU specificities into account, its proposal is not yet in line with the mandate given to the…

Consultation response

Mouvement des Entreprises de France, 18 Dec 2019

While the European Union faces huge challenges in ensuring the energy, ecological and digital transition of its economy and financing the hundreds of billions of euros of necessary investments, Medef is extremely concerned about the consequences of the transposition of the Basel agreements of…

Consultation response

Association Française des Entreprises Privées / French Association of Large Companies, 18 Dec 2019

AFEP – the French Association of Private Enterprises – represents 113 of the largest private corporations operating in France and takes part in the public debate in order to provide pragmatic solutions to develop a competitive French and European economy. While the European Union is about to…

Consultation response

Alstom, 22 Feb 2022

Please find attached Alstom's contribution.

Consultation response

Finance Watch, 23 Feb 2022

Finance Watch welcomes the initiative of the EU co-legislators to proceed with the implementation of the final instalment of the Basel III standards. We note, however, that the primary and overarching objective of the Basel III process – to restore financial stability and protect EU citizens and…

Consultation response

Associazione Bancaria Italiana, 18 Dec 2019

Please find here enclosed the comments of the Italian Banking Association to the EU Commission “Inception impact assessment” relating to the initiative “Amendments to the Capital Requirements Regulation and the Capital Requirements Directive”

Consultation response

Asociación Española de Banca, 23 Feb 2022

The Spanish Banking Association (AEB) welcomes the European Commission proposal for the EU transposition of the “Basel III: Finalizing post-crisis reform” standard. AEB acknowledge the efforts made by the EU regulators to achieve several goals such as: - Reducing the impact in terms of capital…

Consultation response

Finance Denmark, 11 Feb 2022

Finance Denmark has submitted a joint response to the Commission’s consultation together with the Swedish Bankers’ Association and Finance Finland. In the proposal, the Commission has chosen an approach for the output floor that applies the floor also on capital requirements beyond the capital…

Consultation response

Finance Denmark, 18 Dec 2019

Please see the attached file with the Finance Denmark answer.

Consultation response

European Association of Co-operative Banks, 23 Dec 2021

The fundamental problem of the implementation of the latest Basel standards resides in choices made at Basel level which make an adequate EU implementation challenging. The EACB acknowledges the Commission’s efforts to reduce the expected impact of reforms on the EU banking and credit markets and…

Consultation response

European Savings and Retail Banking Group, 22 Feb 2022

The European Savings and Retail Banking Group (ESBG) positively assesses the banking package proposal issued by the European Commission. It transposes the final elements of the Basel III reforms in the EU regulatory framework and it pursues other prudential and supervisory objectives. Whilst the…

Consultation response

European Association of Public Banks and Funding agencies AISBL, 14 Feb 2022

We welcome the proposed measures that limit the negative effects of the regulatory framework on bank’s capital requirement and thus on the real economy (e.g., the retention of specific treatments, the implementation periods and the relief for banks when calculating the output floor (OF)). In the…

Consultation response

Swedbank AB (publ), 22 Feb 2022

Swedbank supports the responses to the Have your say consultation from the European Banking Federation, the European Savings and Retail Banking Group, and the group of three Nordic banking associations (Finance Denmark, the Swedish Bankers Association, and Finance Finland). We support the…

Finance Sweden Warns Capital Rules May Hike Nordic Financing Costs

Finance Sweden, 16 Feb 2022

The organization calls for a permanent and more risk-sensitive implementation of the output floor for loans. They argue that temporary adjustments for unrated companies and residential mortgages should be made permanent to reflect market structures.
This would prevent a sharp rise in capital requirements and maintain Nordic banks' competitiveness.
Homeowners and businesses face higher costs and reduced access to bank lending for investments.

Consultation response

European Federation of Building Societies, 18 Feb 2022

The European Federation of Building Societies (EFBS) is an association of credit and other institutions promoting and supporting the financing of home ownership. Its purpose is to encourage the idea of acquiring home ownership in Europe that is converging both politically and economically. Before…

BNY Mellon Urges Excluding Asset Managers From Banking Rules

The Bank of New York Mellon, 18 Dec 2019

The bank requests that asset managers be excluded from certain banking parent requirements. They argue these firms are not bank-like and inclusion creates an unlevel playing field. They also suggest allowing more flexibility for capital buffers in bank subsidiaries.
This would reduce administrative costs and prevent unnecessary lock-up of capital across jurisdictions.
Financial regulators lose the security of a fixed and higher mandatory capital safety net.

Consultation response

Association européenne du cautionnement, 21 Feb 2022

Please find our detailed position paper enclosed

Consultation response

Futures Industry Association, Inc., 23 Feb 2022

FIA is the leading global trade organization for the futures, options and centrally cleared derivatives markets, with offices in Brussels, London, Singapore and Washington, D.C. FIA’s membership includes clearing firms, exchanges, clearinghouses, trading firms and commodities specialists from about…

Consultation response

International Chamber of Commerce, 20 Jan 2022

International Chamber of Commerce (ICC) The International Chamber of Commerce (“ICC”) – the institutional representative of more than 45 million businesses in over 130 countries – warmly welcomes the objectives of the proposed Capital Requirements Regulation (“CRR3”). As a global organization, we…

Consultation response

Verband deutscher Pfandbriefbanken e.V., 6 Jan 2022

The Association of German Pfandbrief Banks thanks for the opportunity to comment briefly on the proposals to amend the CRR and has summarised its comments in the annex.

ASF urges tailored capital rules for specialized financial institutions

Association française des sociétés Financières, 22 Feb 2022

The ASF requests including smaller firms in risk reports and accelerating credit insurance reviews. They also want home loan guarantees to be treated as equivalent to mortgages.
This would ensure specialized French lenders avoid operational barriers and higher capital costs.
Regulators lose the stricter oversight ensured by requiring guarantees to meet bank-level capital standards.

Consultation response

Die Deutsche Kreditwirtschaft, 21 Dec 2021

The German Banking Industry Committee welcomes in principle the legislative proposal published on 27 October 2021 by the European Commission, the so-called Banking Package 2021, to implement the final elements of the Basel III reforms in the EU regulatory framework. The EU Commission's proposal for…

Consultation response

European Development Finance Institutions, 23 Feb 2022

Cf. the attached position paper and presentation

Mortgage lenders urge changes to prevent hike in housing costs

European Mortgage Federation - European Covered Bond Council, 16 Dec 2021

The Federation requests making beneficial mortgage risk treatments permanent for all banks. They also propose a granular risk-weighting framework to prevent sharp capital increases.
This would lower capital requirements for lenders and protect their mortgage lending volumes.
National regulators would lose the power to set specific local capital requirements.

Consultation response

China Chamber of Commerce to the EU, 3 Feb 2022

The China Chamber of Commerce to the EU (CCCEU) is a business organisation that gathers Chinese-invested corporations in Europe. As such, the CCCEU speaks on behalf of about 1,000 Chinese enterprises in the EU. Its mission is to promote China-EU economic cooperation, to increase the mutual…

Consultation response

International Credit Insurance & Surety Association, 21 Feb 2022

The International Credit Insurance and Surety Association is the global trade association representing the leading providers of trade credit insurance and surety internationally. Our members provide services worldwide, but given the prominence of European markets, the majority of our trade credit…

Consultation response

European Association of Corporate Treasurers, 22 Feb 2022

The European Association of Corporate Treasurers (“EACT”) – which brings together 24 national associations, representing over 6.500 companies across Europe – welcomes the objectives of the review of the banking framework which should contribute to ensuring financial stability and economic growth.…

Consultation response

Triodos Bank, 21 Dec 2021

1. Floors strengthen a diverse banking system. We have been looking forward to the final implementation of Basel III, especially the implementation of the floors. It would protect the financial system against a race to the bottom; the diversity in the banking landscape of large and small players,…

Consultation response

Confederación Española de Cajas de Ahorros (CECA), 23 Feb 2022

CECA (Spanish Association of Savings and Retail Banks) welcomes the opportunity to comment on the Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) No 575/2013 as regards requirements for credit risk, credit valuation adjustment risk, operational risk,…

Consultation response

Fédération Nationale des Travaux Publics, 23 Feb 2022

The finalisation of the Basel III accords should recognise the specificities of the EU banking sector. It should pragmatically apply the output floor at the consolidated level. Banks play a key role in infrastructure financing in the EU, while in the US infrastructure projects are mainly financed…

Consultation response

Verband Deutscher Bürgschaftsbanken e.V., 23 Feb 2022

Zentrale Forderungen der angehängten Stellungnahme: - Förderinstitute wie die Bürgschaftsbanken müssen bei EK-Anforderungen Regelungen bzgl. Verzicht auf Ratings und Sitzlandberücksichtigung behalten - Empfehlungscharakter der Formulierung zum Granularitätskriterium muss erhalten bleiben -…

Consultation response

International Securities Lending Association, 23 Feb 2022

The International Securities Lending Association (ISLA) welcomes the finalisation of the Basel III reforms in the European Union to further contribute to future financial stability and assist in the steady crisis recovery, post COVID-19. The International Securities Lending Association (ISLA) is…

Consultation response

European Network of Credit Unions, 17 Dec 2019

See, attached file.

Consultation response

BAFT (Bankers Association for Finance and Trade), 23 Feb 2022

BAFT (The Bankers Association for Finance and Trade) welcomes the opportunity to comment on the “Banking Package” released on 27 October 2021 which includes a legislative proposal COM(2021)664, intended to amend Regulation (EU) No 575/2013 (Capital Requirements Regulation, CRR). BAFT is an…

Consultation response

European AVM Alliance, 23 Feb 2022

EAA Response to the European Commission’s Public Consultation on “Implementing the final Basel III Reforms in the EU” The European AVM Alliance AISBL (EAA) is a European federation consisting of leading providers of Automated Valuation Models (AVMs). The EAA's main aim is to bring about a…

Consultation response

Association Française des Trésoriers d'Entreprise, 23 Feb 2022

AFTE is the French Association of Corporate Treasurers representing the corporate treasury activities of non-financial companies or corporates (“NFCs”) including Small to Medium Sized Enterprises (“SMEs”). AFTE welcomes the effort of the European Commission to implement the Basel 3 text and…

Consultation response

Lloyd's Market Association, 22 Feb 2022

The Lloyd's Market Association (LMA) exists at the very heart of Lloyd's, a world-leading global marketplace for complex risk where solutions to challenges are delivered every day. All 51 Lloyd's managing agencies, who write approximately £36 billion of premium per annum, and all Lloyd's members…

Consultation response

EU Federation for the Factoring and Commercial Finance Industry, 22 Feb 2022

The EUF welcomes the opportunity to provide its comments on the proposed amendments to the CRR aimed to finalize the Basel III framework. In this perspective, the EUF believes that the European Commission should consider the following comments and proposals: • On the definition of “ancillary…

Consultation response

International Valuation Standards Council, 21 Feb 2022

The CRR Prudent Property Valuation Approach The International Valuation Standards Council (IVSC) is the independent global standard setter for the valuation profession. The IVSC set International Valuation Standards which promote consistency and professionalism in the public interest. The…

Consultation response

Royal Institution of Chartered Surveyors, 18 Feb 2022

The CRR Prudent Property Valuation Approach The Royal Institution of Chartered Surveyors (RICS) have over 134,000 highly qualified trainees and professionals, many operating globally as property valuers and appraisers. Through our respected global standards, leading professional progression and…

Consultation response

International Association of Credit Portfolio Managers, 16 Feb 2022

IACPM (International Association of Credit Portfolio Managers) appreciates the opportunity to provide feedback on the 2021 Banking Package. We are a global association of credit portfolio managers of which more than half of the membership is comprised of European financial institutions, mainly…

Consultation response

Verband der Auslandsbanken in Deutschland e.V. / Association of Foreign Banks in Germany, 16 Feb 2022

Art. 4 (1) point (145) CRR should be amended as to include a de minimis threshold. Institutions with a balance sheet total of under € 750 million should be able to obtain the status as small and non-complex regardless of whether the criterion (f) is met, according to which more than 75 % of both…

Consultation response

, 15 Dec 2021

The French Banking Federation (FBF) welcomes the proposal of the European Commission for the review of the Capital Requirements Regulation and Directive in the context of the Banking Package. The proposal is not yet in line with the mandate given by the G20, the Council and the European Parliament…

Consultation response

Association Française des Trésoriers d'Entreprise, 18 Dec 2019

AFTE is the French Association of Corporate Treasurers representing the corporate treasuries of non financial companies (about 1 000 French members). We welcome the effort to increase the resilience of the EU financial system but we would urge for a careful risk based analysis of prudential…