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ABN AMRO Bank N.V.

ABN AMRO

ABN AMRO is a full-service bank in the Netherlands that offers a broad range of products and services to retail, private and corporate banking clients.

Lobbying Activity

Meeting with Karmenu Vella (Commissioner) and

2 May 2017 · Blue Economy Financing Principles

Response to Extension of transitional period for CCPs

15 Nov 2016

ABN AMRO Clearing Bank N.V. (AACB) requests and strongly supports an extension of the QCCP transitional period to 15 June 2017. This extension will enable a thorough assessment of the jurisdictions that remain subject to an equivalence determination. AACB and its clients are strong proponents of the current and future equivalence process that enables a level playing field for global financial markets based on how other countries have implemented the global Principals for Financial Market Infrastructure (PFMI) standards of the Basel Committee for Banking Supervision (BCBS) and CPMI/IOSCO. AACB appreciates the fact that equivalence assessments with a large number of jurisdictions, including Singapore, Hong Kong and Australia, have now been completed. This means that CCPs in these jurisdictions will be classified as QCCPs and are subject to a more realistic risk weighting (RWA). At the same time, AACB and its clients have been increasingly concerned about a perceived lack of progress in the equivalence process with the United States of America. While an agreement was reached between the European Commission (EC) and the Commodity Futures Trading Commission (CFTC), no agreement has yet been reached with the Securities and Exchange Commission (SEC), which is responsible for oversight and supervision of, amongst other self-regulatory organizations, the Options Clearing Corporation (OCC) and the Depository Trust & Clearing Corporation (DTCC). AACB is one of the largest European General Clearing Member (GCM) on the OCC, clearing for a large number of US market makers and liquidity providers on the markets cleared by the OCC. AACB and its clients are concerned that the consequence of exposure to a Non Qualifying CCP (N-QCCP) is a significantly higher RWA based on trade and default fund exposure. If the OCC is not able to obtain QCCP status, trade exposure to the OCC alone will lead to billions of additional RWA and, ultimately, cause a wind-down of the AACB activities on this CCP. As a result, the liquidity provision activities of a large number of market makers that are active on the markets cleared by the OCC will be significantly constrained. AACB believes that the prolonged lack of an agreement with the SEC could lead to severe market and liquidity disruptions for the following reasons: • Non-bank market makers and liquidity providers have become a critical source of liquidity in the global financial infrastructure; they play a key role in contributing to stable, reliable, efficient and well-functioning markets and have largely replaced merchant banks, which have ceased such activities as a result of regulatory and capital pressure; • There are currently only a small number of GCMs that provide clearing services to market makers and liquidity providers as a result of the impact of the Basel III requirements, most notably the leverage ratio; • If the number of GCMs decreases further, leaving only one or two GCM providing such services, fragility would be introduced and market makers and liquidity providers would be severely restricted in their activities as they would have a harder time sourcing financing and/or guarantees. In the long term, this could lead to less liquidity in the market for the general investing public and higher costs (spread width) to enter the market. In summary, AACB and its clients believe that failure to reach an agreement with the SEC will have unintended material effects on AACB and its clients based on their exposure to the OCC. We therefore welcome an extension to June 2017 in order to allow sufficient time for the SEC to gain equivalence and the OCC to gain recognition. At the same time, we kindly request to the European Commission, ESMA and the SEC to conclude equivalence assessments as a matter of priority. AACB is supported in this position by Optiver US LLC, DRW Securities LLC, IMC-Chicago LLC, Akuna Securities LLC and CTC Trading Group LLC.
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

27 Oct 2016 · EU financial services regulation

Meeting with Frans Timmermans (First Vice-President) and KLM Royal Dutch Airlines and

27 Feb 2015 · Better regulation and European affairs in general

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

24 Feb 2015 · Introduction meeting with a focus on level 2 and retail banking