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Association for Financial Markets in Europe

AFME

AFME represents Europe's wholesale financial markets, advocating for deep and integrated European capital markets that serve companies and investors.

Lobbying Activity

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

13 Jan 2026 · Market integration and supervision package

Meeting with Jennifer Robertson (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

13 Jan 2026 · CSDR : SIU proposal

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

Our feedback is included in the attached file.
Read full response

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

26 Nov 2025 · Capital Markets Union (CMU)

Meeting with Michalis Hadjipantela (Member of the European Parliament)

20 Nov 2025 · Meeting about Taxonomy Delegated Act

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

7 Nov 2025 · Securitisation

Meeting with Giovanni Crosetto (Member of the European Parliament, Shadow rapporteur) and Unipol Assicurazioni S.p.A:

21 Oct 2025 · Securitisation Framework

Meeting with Gilles Boyer (Member of the European Parliament)

21 Oct 2025 · Banking Union

Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

15 Oct 2025 · SIU

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union)

15 Oct 2025 · The development of the EC’S SIU strategy

AFME Demands Sectoral Exemption from EU Cyber Resilience Act

14 Oct 2025
Topic — A consultation on simplifying digital regulations and reducing administrative burdens for businesses.
Message — AFME requests a sectoral exemption from the Cyber Resilience Act to avoid significant overlap with existing financial resilience rules. They also seek a revision of the implementation timeline for the AI Act to ensure legislation is delivered as thoroughly as possible. Finally, they advocate for a market-driven approach to financial data sharing.123
Why — This would eliminate redundant compliance costs and protect firms from duplicative reporting burdens.45
Impact — Digital gatekeepers lose out as the proposal seeks to exclude them from data-sharing regimes.6
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

14 Oct 2025 · Simplification

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

14 Oct 2025 · Simplification

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

13 Oct 2025 · Securitisation

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

10 Oct 2025 · SIU: equity trading structure

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

9 Oct 2025 · Digital omnibus

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

2 Oct 2025 · Securitisation – AFME’s comments on the Commission’s securitization package

Meeting with Ralf Seekatz (Member of the European Parliament, Rapporteur) and Asociación Española de Banca and Schroders Investment Management (Europe) SA

1 Oct 2025 · Verbriefung

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

24 Sept 2025 · Level 2 measures

Meeting with Jennifer Robertson (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

11 Sept 2025 · CSDR

Response to Delegated Regulation supplementing the review of prudential rules for the insurance and reinsurance sector (Solvency II)

5 Sept 2025

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to provide feedback on the European Commission's draft amendments to the Solvency II Delegated Regulation. Please find our feedback in our consultation response and the accompanying impact analysis, both uploaded/attached to this response form.
Read full response

Meeting with Angelika Niebler (Member of the European Parliament)

24 Jul 2025 · Omnibus I, CSRD and CSDDD

Finance Industry Backs Auto-Enrolment Pensions with Tax Incentives

18 Jul 2025
Topic — EU recommendation on auto-enrolment and tracking systems for supplementary pensions.
Message — AFME recommends that member states promote auto-enrolment supplementary pension schemes with opt-out options and attractive tax incentives. They suggest state-wide administration facilities and flexible contribution rates that can increase gradually over time.123
Why — This would direct retail savings into capital markets and productive investments.45
Impact — Public budgets lose short-term revenue from tax incentives for pension schemes.6
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Financial industry urges lower haircuts for securitisation HQLA eligibility

15 Jul 2025
Topic — Amendments to Liquidity Coverage Ratio rules for securitisation eligibility in bank liquidity buffers.
Message — AFME requests lower haircuts for securitisations in banks' liquid asset buffers. They propose 15% for standard STS securitisations and 10% for resilient STS transactions. They also seek removal of the requirement that securitisations must be STS-labelled to qualify.1234
Why — This would allow their members to hold more securitisations as liquid assets with lower capital charges.56
Impact — Not clearly specified who would be harmed by these proposed changes to technical liquidity requirements.
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Financial industry urges inclusion of carbon removals in EU ETS

8 Jul 2025
Topic — Review of EU Emissions Trading System and Market Stability Reserve regulations.
Message — The organizations want permanent carbon removals certified under the CRCF allowed for EU ETS compliance. They support direct purchase of removal credits by regulated entities and phased integration with safeguards. They also advocate for linking EU and UK carbon markets.123
Why — This would provide their members more cost-effective compliance options and improve market liquidity.45
Impact — Climate integrity could suffer if removals substitute for actual emissions reductions.6
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Financial industry urges flexible EU investment account framework

8 Jul 2025
Topic — European Commission proposal for standardized savings and investment accounts across EU member states.
Message — AFME requests flexibility in account features, allowing frameworks with varied investment universes and holding periods. They advocate for simple account structures, attractive tax incentives, and portability between providers. The organization wants existing successful schemes preserved rather than replaced.123
Why — This would enable their members to scale products across borders and reduce operational costs.4
Impact — Advocates for directing capital to EU economy lose stricter investment requirements and holding periods.5
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Meeting with Gilles Boyer (Member of the European Parliament)

8 Jul 2025 · SIU, securitisation, omnibius simplification

Meeting with Jonás Fernández (Member of the European Parliament)

8 Jul 2025 · Saving and Investment Union

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

7 Jul 2025 · MiFIR – market consolidation

Meeting with Yann Germaine (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

26 Jun 2025 · Exchange of views on the reform of the bank crisis management and deposit insurance framework (CMDI review)

Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology)

25 Jun 2025 · State of play on cloud policy

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

12 Jun 2025 · DLT pilot review

Meeting with Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

22 May 2025 · Exchange with AFME on the Retail Investment Strategy

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

21 May 2025 · Firseside chat on the state-of-play of the Sustainable Finance framework

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Banco Santander, S.A. and

14 May 2025 · Informal Workshop on the integration of EU capital market

Meeting with Matthias Ecke (Member of the European Parliament, Rapporteur)

24 Apr 2025 · Finanzmarkt-Besteuerung

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and Insurance Europe and

22 Apr 2025 · FIDA

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

16 Apr 2025 · Financial services policies

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

3 Apr 2025 · Exchange of views on the FIDA proposal

Financial industry urges suspension of Green Asset Ratio

26 Mar 2025
Topic — EU simplification of Taxonomy reporting requirements for sustainable finance disclosures.
Message — The associations request suspension of the Green Asset Ratio (GAR) pending a full review, removal of Fees & Commissions and Trading Book KPIs, and elimination of GAR from Pillar 3 disclosures. They argue the GAR does not provide meaningful information yet creates significant operational burdens for banks and their clients.123
Why — This would eliminate very substantial resource requirements and operational exercises for banks.45
Impact — Investors lose standardized metrics for comparing banks' sustainable finance contributions and green asset exposure.6
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Response to Review of the Securitisation Framework

26 Mar 2025

The Association for Financial Markets in Europe (AFME) welcomes the Commissions holistic review of the securitisation framework. Our response to the Call for Evidence focuses specifically on the prudential treatment of securitisation for banks and insurers. Please refer to the uploaded file which contains detailed evidence, data and supporting explanations. Our feedback is summarised below. AFME advocates for a review of the Solvency II capital calibration in relation to securitisation exposures. Whilst we welcome the risk-sensitivity introduced in the senior STS segment by Commission Delegated Regulation (EU) 2018/1221, the current capital charges for non-STS and non-senior STS are disproportionate to their risk (please see p. 6-7 of the uploaded file). This significantly reduces the attractiveness of most securitisation investments for EU insurers (see p. 8-10), and the data indicates a notable disinvestment after Solvency II came into effect in 2016 (see p. 5). In the non-STS and non-senior STS segments, with the miscalibrated capital charges on investment grade tranches, the Solvency II regime has the effect of creating unintended incentives to invest further down the capital structure (see p. 13-14). In the senior STS market, where capital charges are lower, insurers take-up is limited by the cliff risk of holding 10-12x more regulatory capital if the position loses its STS label and thus incurs non-STS capital charges, as well as low supply in the market (see p. 11). Owing to these disincentives to invest in the securitisation market, insurers are restricted in the diversification of their investment portfolios which leads to greater concentration risk that neither serves the interests of policyholders nor shareholders. We address the perception amongst some stakeholders that the capital calibration does not matter by evidencing the disparity between the securitisation investments of standard formula vs. internal model insurers in the EU, the latter of whom face more risk-sensitive capital charges (see p. 12). Whilst some stakeholders believe that the costs of changing the Solvency II framework exceed the potential benefits, we provide evidence that insurers are interested in the market but have been deterred by disproportionate capital charges (see p. 5), and we estimate that a more risk-sensitive, proportionate Solvency II framework has the potential to unlock EUR 130 210 billion in additional financing to the real EU economy, with a multiplier effect on EU households, SMEs and corporates (see p. 16). Lack of risk sensitivity in Solvency II is not the only example of regulation impeding investors ability to diversify. For example, the existing application of a 10% limit on UCITS investment at the level of the ABS transaction also creates obstacles, and we would therefore suggest removing it. With respect to the prudential treatment of securitisation for banks, our bank capital impact analysis demonstrates that the shape and steepness of the so-called cliff-edge effect, as described in the 2022 JC Report, does not reflect the market reality of banks exposure to securitisation risk. Whilst micro-thin mezzanine tranches are most vulnerable to the cliff-edge effect, banks are predominantly exposed to senior securitisation risk as part of their core business, which entails significantly lower risk (>10x lower) than what was identified in the JC Report. In this context, our proposal to amend the SEC-IRBA p floor to 0.1 for STS and 0.25 for non-STS, as well as to our recommendation to adjust the SEC-SA p-factor to 0.25 for STS and 0.5 for non-STS, appear reasonable in relation to financial stability. Finally, whilst we have focused on the prudential framework here, we would like to highlight that no singular measure has the potential to increase the use and attractiveness of securitisation by itself. Only a package of measures can collectively set in motion the revival of the securitisation market in the EU.
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Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

26 Mar 2025 · Banking policy

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Shadow rapporteur)

25 Mar 2025 · FIDA

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

19 Mar 2025 · Discussion on transaction reporting

Financial markets association urges permanent low funding requirements for repos

6 Mar 2025
Topic — EU rules on securities financing transactions for net stable funding ratio calculations.
Message — AFME wants the EU to permanently maintain current 0%, 5% and 10% required stable funding factors for reverse repos and unsecured lending. They argue reverting to higher Basel Committee standards would harm securities dealing and increase government borrowing costs.12
Why — This maintains lower funding costs for their sovereign bond market-making activities.3
Impact — European governments face higher borrowing costs to finance their economic needs.4
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Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Insurance Europe and

4 Mar 2025 · EU financial services industry associations debrief on EU-UK Financial Regulatory Forum

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

4 Mar 2025 · Exchange of views on the FRTB international implementation

Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

27 Feb 2025 · Simplification, Savings and Investments Union, Distributed Ledger Technology

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Deutsche Bank AG and

13 Feb 2025 · Discussion on level 2 measures on transparency requirements for equity and non-equity instruments, synchronisation of business clocks, transaction reporting and best execution

Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament)

13 Feb 2025 · Sustainable finance

Meeting with Jonás Fernández (Member of the European Parliament)

13 Feb 2025 · Saving and Investment Union

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

12 Feb 2025 · Meeting to discuss market developments

Meeting with Gilles Boyer (Member of the European Parliament)

12 Feb 2025 · Banking legislation

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

11 Feb 2025 · Sustainability Omnibus

Meeting with Christophe Gomart (Member of the European Parliament)

11 Feb 2025 · Financement de la défense

Meeting with Billy Kelleher (Member of the European Parliament)

11 Feb 2025 · Savings and Investment Union

Meeting with Mattias Levin (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Banco Santander, S.A. and The Goldman Sachs Group, Inc.

5 Feb 2025 · Use of DLT and Tokenisation in Financial Markets

Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

5 Feb 2025 · AFME's Annual Financial Services Policy Dinner

Meeting with Antonina Cipollone (Head of Unit Secretariat-General)

16 Jan 2025 · Simplification

Meeting with Kinga Kollár (Member of the European Parliament)

15 Jan 2025 · Role of the CMU to improve the competitiveness of EU’s companies and EU’s banking regulation priorities

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and BNP PARIBAS and The Goldman Sachs Group, Inc.

14 Jan 2025 · Commodity derivatives

Meeting with Dirk Gotink (Member of the European Parliament)

13 Jan 2025 · CMU and banking regulation

Meeting with Maria Raffaella Assetta (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Insurance Europe and

9 Jan 2025 · EU-UK Financial Regulatory Forum

Meeting with Aurore Lalucq (Member of the European Parliament)

8 Jan 2025 · CMU, Securitization

Meeting with Gilles Boyer (Member of the European Parliament)

19 Dec 2024 · Securitisation

Meeting with Gilles Boyer (Member of the European Parliament) and Insurance Europe and

3 Dec 2024 · CMU

Meeting with Regina Doherty (Member of the European Parliament)

16 Jul 2024 · Financial services

Meeting with Eva-Maria Alexandrova Poptcheva (Member of the European Parliament, Committee chair)

10 Jan 2024 · Meeting regarding the Integration, Sustainability and Competitiveness report

Meeting with Jonás Fernández (Member of the European Parliament)

30 Nov 2023 · Capital markets union, securitisation and sustainable finance

Meeting with Billy Kelleher (Member of the European Parliament, Shadow rapporteur)

16 Nov 2023 · ESG Rating Transparency

Meeting with Frances Fitzgerald (Member of the European Parliament, Shadow rapporteur)

10 Nov 2023 · FIDA

AFME Urges Market-Driven Compensation and Longer Open Finance Timeline

1 Nov 2023
Topic — New EU regulation on financial data sharing and third-party access to financial sectors.
Message — AFME requests narrowing data scope to exclude inferred data and wholesale corporate clients. They propose a 48-month implementation timeline and market-driven compensation.123
Why — This avoids sharing sensitive intellectual property and reduces the burden of real-time requirements.45
Impact — Big Tech gatekeepers and medium-sized companies would face market exclusion or higher access costs.67
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Financial Industry Seeks Clearer Rules on EU Withholding Tax Reform

18 Sept 2023
Topic — New EU directive on standardised withholding tax relief and faster refunds for cross-border investors.
Message — AFME requests clear, consistent reporting requirements and due diligence obligations across Member States, with a single EU-wide portal for registration and reporting. They emphasize that liability rules must recognize the limits of financial intermediaries' visibility into investor activities. The organization also seeks clarification on key definitions including beneficial ownership, financial arrangements, and holding periods.1234
Why — This would reduce their compliance costs and operational complexity across twenty-seven countries.56
Impact — Tax authorities could lose revenue if intermediaries lack visibility into abusive arrangements.7
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Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme

15 Sept 2023 · Retail investment strategy

Meeting with Mairead McGuinness (Commissioner) and

14 Sept 2023 · banking regulation, Corporate Sustainability Due Diligence Directive

Finance Industry Seeks Clarity on ESG Rating Rules

1 Sept 2023
Topic — EU regulation on transparency and integrity of ESG rating activities.
Message — AFME requests the scope be clarified to avoid capturing regulated financial undertakings already subject to existing requirements. They seek efficient interactions between ratings providers and rated entities, and a workable third-country regime with interoperable requirements.12
Why — This would exempt their members from duplicative regulatory requirements they already face.3
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

29 Aug 2023 · T+1 Settlement Cycle, MifiR

AFME Warns EU Retail Rules Could Damage Capital Markets

28 Aug 2023
Topic — The consultation covers legislative proposals to increase retail investor participation in capital markets.
Message — AFME urges replacing prescriptive cost benchmarks with a flexible, outcomes-based approach. They request that inducement bans be clarified to protect wholesale distribution and support services.12
Why — This would preserve existing revenue streams and avoid the risk of product blacklisting.345
Impact — Retail investors could face fewer investment choices and new costs for support services.67
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Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

AFME Urges Solution for Missing Sustainability Data in Reporting

7 Jul 2023
Topic — The consultation concerns the first set of mandatory sustainability reporting standards for European companies.
Message — AFME requests a solution for reporting data that companies omit but banks legally require. They propose extending the value chain phase-in period by two additional years. They also urge better alignment between European and international standards.123
Why — This would lower compliance costs and shield financial institutions from legal risks regarding data.45
Impact — Transparency advocates lose out if banks report zero instead of quantifying actual sustainability impacts.67
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Meeting with Eva-Maria Alexandrova Poptcheva (Member of the European Parliament, Shadow rapporteur)

15 May 2023 · Listing Act

Meeting with Alfred Sant (Member of the European Parliament, Rapporteur)

9 May 2023 · Listing Act

AFME urges one-year delay for bank taxonomy reporting

3 May 2023
Topic — This consultation establishes technical criteria for sustainable activities and financial sector reporting requirements.
Message — AFME requests delaying the reporting timeline for financial firms until 2025. This would allow banks to first collect data from the companies they finance. They also want clearer definitions for project loans and uniform reporting forms.12
Why — Banks would avoid significant operational burdens and the risk of publishing misleading information.34
Impact — EU regulators lose early visibility into how financial institutions support environmental goals.5
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Banking Industry Opposes EU Prospectus Length Caps and Disclosure Exemptions

28 Mar 2023
Topic — Proposed EU directive simplifying listing requirements to attract companies to public markets.
Message — AFME strongly opposes blanket proposals to cap prospectus length and remove prospectus requirements for secondary capital raises under 40%. They argue these create material risks for investors and market stability. They support certain targeted simplifications like shorter IPO prospectus availability and lower free float requirements.123
Why — This would reduce their liability and litigation risks from incomplete disclosure documents.45
Impact — Investors lose access to complete information needed for informed investment decisions.67
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Finance Industry Seeks Changes to EU Crypto Tax Reporting Rules

28 Mar 2023
Topic — EU proposal to expand tax cooperation directive to include crypto-assets and e-money.
Message — The organization requests removal of extraterritorial reporting requirements for non-EU firms, alignment of reporting deadlines with existing tax regimes, and elimination of mandatory taxpayer identification numbers. They argue current proposals create conflicts with data protection laws and operational burdens.12345
Why — This would reduce compliance costs by avoiding duplicate reporting systems and data conflicts.67
Impact — Tax authorities lose timely information on crypto transactions that could identify evasion.8
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Finance industry seeks flexibility in EU insolvency reform

17 Mar 2023
Topic — New EU directive harmonizing national insolvency laws to facilitate cross-border investment.
Message — The organization requests removal of mandatory court approval for asset sales and creditor committees, greater clarity on directors' permitted actions during the three-month filing period, and a safe harbour for directors trying to save companies. They want insolvency proceedings that are simpler, more efficient, and more certain.123
Why — This would enable faster, cheaper insolvency proceedings without navigating court processes.45
Impact — Debtors lose protections against rushed asset sales and potential abuse without court oversight.6
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

28 Feb 2023 · Capital Markets Union

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

9 Feb 2023 · CRR (staff)

Meeting with Danuta Maria Hübner (Member of the European Parliament)

25 Jan 2023 · Speech at AFME Financial Services Policy Dinner

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

16 Dec 2022 · CRR3 (staff)

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

18 Nov 2022 · MiFIR, EU bond market liquidity

Meeting with Mairead McGuinness (Commissioner) and

17 Nov 2022 · Capital Markets Union

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

4 Oct 2022 · CRR3 (staff)

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur)

8 Jun 2022 · EU Banking Package 2021

Financial industry opposes inducement ban and expanded disclosure rules

31 May 2022
Topic — EU measures to boost retail investor confidence and capital market participation.
Message — The association opposes banning inducements and expanding disclosure requirements beyond current products. They argue existing rules provide adequate protection and warn reforms could reduce product diversity and increase costs for investors.1234
Why — This would preserve their commission-based business model and avoid costly compliance changes.56
Impact — Retail investors lose protections against conflicted advice and misleading product comparisons.7
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Financial Markets Industry Urges Halt to Mandatory Buy-in Rules

26 May 2022
Topic — EU regulation on settlement discipline for securities transactions and CSD operations.
Message — AFME requests that mandatory buy-ins not be implemented, arguing other policy tools are more appropriate for improving settlement efficiency. They support measures to prevent settlement fails, including improved CSD functionality and harmonization. If buy-ins must remain, they should be a last resort with substantial revisions to the rules.123
Why — This would avoid negative impacts on liquidity and maintain competitiveness in EU markets.45
Impact — Investors lose protection against persistent settlement failures and market inefficiency.67
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Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur) and Asociación Española de Banca

23 May 2022 · EU Banking Package 2021 - "Basel III rules" panel discussion

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

26 Apr 2022 · sustainable finance

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

26 Apr 2022 · sustainable finance

Finance industry seeks exemptions from shell entity rules

6 Apr 2022
Topic — EU directive preventing misuse of shell entities for tax avoidance purposes.
Message — AFME requests exemptions for legitimate commercial arrangements and alignment with non-EU rules. They want clear definitions, procedural protections for rebutting shell presumptions, and harmonized standards across Member States to avoid fragmentation.123
Why — This would reduce compliance costs and avoid double taxation on legitimate cross-border investments.45
Impact — Tax authorities lose tools to combat shell companies used for aggressive tax avoidance.6
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

29 Mar 2022

Please see attached document ("AFME Financial transparency – single EU access point for company information Final draft.docx").
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

18 Mar 2022 · Banking Package, consolidated tape

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur) and UniCredit

3 Mar 2022 · EUGB (staff)

Meeting with José Gusmão (Member of the European Parliament, Shadow rapporteur)

11 Jan 2022 · EU Green Bond Standard

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

30 Nov 2021 · crypto-assets

Meeting with Pedro Marques (Member of the European Parliament, Shadow rapporteur)

22 Nov 2021 · AMLA

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

29 Oct 2021 · Review of the Markets in Financial Instrument Regulation

Financial industry urges clear beneficial ownership rules for withholding tax

26 Oct 2021
Topic — EU standardized system for withholding tax relief to reduce cross-border investment barriers.
Message — AFME requests clear and consistent beneficial ownership requirements alongside procedural improvements. They argue current uncertainty leads to lengthy disputes and inconsistent outcomes across member states.123
Why — This would reduce lengthy disputes and provide certainty for their members' tax reclaim processes.45
Impact — Tax authorities lose flexibility to challenge claims on beneficial ownership grounds retrospectively.6
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Finance industry urges delay in sustainability reporting for banks

14 Jul 2021
Topic — New EU directive requiring companies to publicly report environmental and social performance information.
Message — AFME requests financial institutions report sustainability information 12 months after non-financial companies complete their reporting. They want phased-in requirements for non-EU exposures and exemptions for third-country operations where counterparties lack disclosure obligations.123
Why — This would give banks time to collect ESG data from borrowers and investees before their own reporting deadlines.45
Impact — Investors and civil society groups receive less comprehensive sustainability information about banks' global operations.67
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Meeting with Mairead McGuinness (Commissioner)

13 Jul 2021 · the forthcoming consolidated tape proposals

Financial industry urges data harmonization before reporting overhaul

14 Jun 2021
Topic — EU strategy to improve supervisory data collection and reduce reporting burden.
Message — The organization requests that authorities establish clear data dictionaries and reduce duplicative reporting before implementing architectural changes. They urge starting with identifying the purpose behind data collection rather than focusing on existing requirements. They advocate maintaining the current push reporting approach rather than moving to a pull model.123
Why — This would reduce compliance costs and allow longer adjustment periods for complex systems.45
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Financial industry urges one-year delay in EU Taxonomy reporting

1 Jun 2021
Topic — EU rules requiring large companies to disclose alignment with sustainable investment taxonomy.
Message — Financial institutions should report 12 months after non-financial companies, not simultaneously. Banks need time to collect, process and verify data from borrowers before disclosing their own exposures. The proposed requirements would force banks to report without access to reliable counterparty information.123
Why — This would give them time to obtain reliable data from clients before reporting.45
Impact — Investors lose earlier transparency on which banks finance sustainable activities most.6
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Financial markets trade body urges focus on indirect retail investment

18 May 2021
Topic — EU strategy to boost retail investor participation in capital markets.
Message — The association requests the Commission recognize that most retail investors access markets indirectly through intermediaries, not through direct investment. They want dialogue on how wholesale banking regulations affect retail investor outcomes.123
Why — This would ensure wholesale banking interests are considered in retail investment policy.4
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

5 May 2021 · with Cab Dombrovskis - Basel III

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and BNP PARIBAS

5 May 2021 · Basel implementation, sustainable finance

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

28 Apr 2021 · CRR3 legislative package

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

27 Apr 2021 · Sustainable Finance

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and BNP PARIBAS and

27 Apr 2021 · MiFIR, EU/UK regulatory and Secondary market liquidity

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Société Générale and

27 Apr 2021 · Sustainable Finance

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

12 Apr 2021 · Substainable Corporate Governance

Response to Central securities depositories – review of EU rules

1 Apr 2021

Settlement Discipline Framework AFME believes that changes to the Settlement Discipline Regime (“SDR”) should be considered the key priority of the CSDR Refit. Although the rules have not yet entered into force, there are fundamental issues with their current form. The CSDR Refit presents a perfect opportunity to make targeted amendments to the SDR to ensure its effectiveness from day one. As noted in our consultation response, most of our concerns relate to the mandatory buy-in regime. Our most critical recommendation is for the mandatory requirement for the buyer to initiate a buy-in to be amended to a discretionary right. The current rules will reduce optionality for end investors, raise transaction costs and damage market liquidity. This will translate to higher costs for European companies seeking access to market-based finance. A discretionary buy-in regime, in combination with well-calibrated cash penalties, will strike the right balance in achieving the objectives of promoting settlement efficiency and protecting the buyer, whilst also mitigating the impact on market liquidity. This is especially important in helping to drive the recovery of Europe’s real economy. As a natural consequence of this, there is a need to defer activation of the buy-in rules to allow for the required legislative amendments to be made prior to activation and for market participants to adapt their technical, operational and legal implementation plans accordingly. Given that the penalty regime and other measures are largely appropriate in their current form, AFME supports their introduction in Feb 2022. We encourage the Commission to provide clarity regarding the implementation timeline at the earliest possibly opportunity, and decouple implementation of the buy-in rules from other measures. Cross-border provision of services within the EU It is critical that barriers to the cross-border provision of CSD services are addressed in order to promote more effective competition between CSDs. AFME agrees that the complexity and cost of the authorisation process, as set out in Articles 23 & 49, is significantly more burdensome than the standard “passporting” process under most EU legislation. We note, however, that the issues cannot be completely resolved through legislative amendment to CSDR. At a national level, there is significant divergence in issuance processes, corporate law requirements, and for the attribution of entitlements. Major improvements will require, inter alia, that the proposals of the Commission’s Action Plan on CMU are put into effect. Key areas are Actions 10 & 12. Internalised Settlement AFME believes that the reporting process is efficient, and that the methodology should not be changed. We note that there are many underlying drivers of the high volume of reported SI activity. These factors should be well understood by authorities when assessing the data. We welcome further opportunity to engage with ESMA and NCAs on this topic. Technological Innovation AFME supports the principle that CSDR should be technology neutral and certain aspects should be amended or clarified where necessary to facilitate the adoption of new technologies. As the market develops, ongoing analysis to identify and address regulatory barriers will be necessary. We believe the DLT Pilot Regime will be useful in identifying further areas in which changes are required to CSDR. AFME has recommended changes to the design of the pilot to reduce regulatory uncertainty and drive innovation and investment. Provision of banking-type ancillary services Any changes to the current rules should not result in a relaxation of the prudential requirements that apply to CSDs providing banking-type ancillary services. We believe that CSDs’ critical role as central market infrastructures for core functions should remain adequately protected from any additional risks, such as credit or market risks, that are normally associated with the provision of banking services
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and JPMorgan Chase & Co. and

16 Mar 2021 · Sustainable finance, Green recovery

Meeting with Marlene Rosemarie Madsen (Cabinet of Commissioner Elisa Ferreira)

24 Feb 2021 · Sustainable Finance

Financial markets lobby urges flexibility in digital resilience rules

15 Feb 2021
Topic — New EU regulation on digital operational resilience for financial institutions and ICT providers.
Message — AFME requests a risk-based approach aligned with existing guidelines, 36-month implementation period, removal of vulnerability disclosure requirements, and elimination of restrictions on third-country providers. They argue prescriptive requirements limit flexibility and increase compliance costs.1234
Why — This would reduce compliance burden and preserve their ability to use global service providers.56
Impact — Regulators lose stronger oversight tools and ability to impose timely security requirements.7
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Response to Legislative framework for the governance of common European data spaces

1 Feb 2021

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commission’s proposal for a Regulation on European Data Governance (Data Governance Act). AFME represents a broad array of European and global participants in the wholesale financial markets. Its members comprise pan-EU and global banks as well as key regional banks, brokers, law firms, investors, and other financial market participants. Please find our consultation response attached, which considers the Data Governance Act in further detail.
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Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

26 Jan 2021 · substainable corporate governance

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

20 Jan 2021 · Digital finance

Meeting with Mario Nava (Director-General Structural Reform Support)

19 Jan 2021 · Update on sustainable finace ou exchange of views on sustainable finance

AFME urges clarity on crypto-asset definitions and custody liability

11 Jan 2021
Topic — EU regulation on markets in crypto-assets and DLT market infrastructures.
Message — AFME requests more technically accurate definitions of DLT and crypto-assets, clearer custody rules, and shorter pilot regime duration with more flexibility. They argue current definitions are too broad and custodial liability requirements are disproportionate, potentially deterring service provision.123
Why — This would reduce legal uncertainty and compliance costs for their members providing crypto-asset services.45
Impact — Investors lose protections if custody standards are weakened or if firms avoid providing services.6
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Financial industry urges flexible approach to EU data transfer rules

10 Dec 2020
Topic — New EU standard contractual clauses for transferring personal data to non-EU countries.
Message — AFME requests flexible, proportionate implementation of new data transfer rules. They seek a three-year grace period for existing contracts, reduced audit burdens, and alignment with GDPR standards. The organization wants costs and liabilities left to commercial negotiation rather than mandated.1234
Why — This would reduce compliance costs and avoid expensive repapering of existing contracts.567
Impact — Data subjects lose stronger oversight as audit requirements and notification thresholds are weakened.89
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Meeting with Mairead McGuinness (Commissioner)

10 Dec 2020 · Presentation AFME, Upconing Sustainable Finance Strategy, Future UK/EU relations.

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

23 Oct 2020 · CMU Action Plan and MiFID

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

17 Sept 2020 · Banking and capital markets

Finance industry urges exemptions from MiFID II research unbundling rules

11 Sept 2020
Topic — EU proposal to adjust MiFID II research rules for SMEs and fixed income instruments post-COVID-19.
Message — The organization requests modifications to the proposed research unbundling exemptions, including narrowing geographic scope to EU-listed issuers only and making the regime optional for both buy-side and sell-side firms. They want simpler definitions for SME issuers using annual assessment dates rather than rolling 12-month periods. For fixed income markets, they seek comprehensive consultation before any changes.1234
Why — This would reduce compliance complexity and system change costs while preserving US regulatory relief.56
Impact — Non-EU issuers lose potential research coverage improvements from the exemption.
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Finance industry urges soft-law approach over AI regulation

10 Sept 2020
Topic — EU proposal for mandatory requirements on artificial intelligence applications and systems.
Message — AFME supports a voluntary, principles-based approach rather than mandatory AI-specific regulation. They argue existing financial services rules already address AI risks through consumer protection, conduct requirements, and operational resilience frameworks. Any new requirements should be limited to genuinely high-risk applications not covered by existing sectoral regulation.1234
Why — This would avoid duplicative compliance costs and preserve their competitive position globally.56
Impact — Citizens lose stronger protections if financial services exempted from high-risk designation.78
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Finance Industry Seeks Cross-Sectoral Data Sharing Framework

31 Jul 2020
Topic — EU legislative framework for governance of common European data spaces.
Message — The organization requests cross-sectoral data sharing rules including digital platforms, improved data portability for users, and API standardization. They emphasize that mandatory sharing requirements should apply equally across sectors to maintain a level playing field.123
Why — This would prevent them facing stricter data sharing obligations than digital platforms.45
Impact — Digital platforms lose their current advantage in accessing financial data without reciprocal obligations.6
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Response to Action Plan on the Capital Markets Union

29 Jul 2020

The Association for Financial Markets in Europe (AFME) welcomes the European Commission’s CMU Roadmap. AFME is a strong supporter of the CMU project. We have provided detailed feedback to the Commission on the strategy for the next phase of CMU in our response to the CMU High-Level Forum recommendations consultation and various other submissions in specific areas. We provide general comments below on selected aspects of the Roadmap. Problem the initiative aims to tackle We concur with the reasoning in the Roadmap on why the CMU is important. We particularly welcome the assessment that the CMU is needed for the EU to build a unique competitive advantage globally as an efficient and well-functioning sustainable capital market. What does the initiative aim to achieve and how We support the list of targeted objectives and the emphasis given to retail investor participation, improving the capital raising ecosystem and enhancing EU integration. Maintaining momentum We agree with the Commission’s assessment that in the aftermath of Covid-19 the CMU should act as a catalyst for mobilising private investments into companies to complement the unprecedented public support agreed on by EU and national authorities. Strong capital markets will also be critical to the green and digital transitions. It will be important to emphasise these aspects to maintain ambition and momentum towards the implementation of the CMU Roadmap. Improving efficiency in wholesale markets In order to make progress in the above areas it is essential to advance the CMU agenda in the sphere of wholesale markets. Improving efficiency and connectivity in securities markets and building a more integrated, open and competitive single market for institutional participants should remain essential components of the CMU as they influence the environment for retail investors and SMEs. These objectives should serve as guiding principles for the future reviews of key legislations such as MiFID 2/R, CSDR and Securitisation Regulation, among others. Building a single capital market and addressing legal and regulatory impediments to integration We also emphasise the importance of creating a common user perception in building a true CMU. By this we mean an environment where users of capital markets (issuers or investors) have the perception of accessing an interconnected capital market through a single user-friendly interface. The challenge today is that users have the perception, and indeed the reality, of having to meet 27 different sets of requirements (legal, operational, tax-related, etc) in order to access EU capital markets, and they have to do the work of understanding all these requirements. Working towards a unified single market environment for end-users should remain a central guiding principle. We also wish to stress the importance of common definitions, a topic addressed in the CMU HLF report. The ideal end state featuring high quality and harmonised securities laws, insolvency, tax and other frameworks is beyond the possibilities of a five-year Action Plan. There should however be a strategy with timelines and objectives to achieve consistent progress towards narrowing harmful frictions and divergences. One important staging post on the road is common definitions of key financial market concepts. This will help future convergence of legislation, and it will help make EU capital markets more understandable to users. Examples of key concepts and processes for common definitions are needed include: “financial instrument”, “shareholder” and withholding tax processes. CMU Key Performance Indicators (KPIs) With the support of other European associations, AFME has led an initiative to develop a set of KPIs to measure progress at national level in advancing the CMU objectives. We believe KPIs will be a valuable tool to understand the evolution of the CMU and assess progress. We welcome the Commission’s continued support for such analysis.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

20 Jul 2020 · Update of the Covid-19 pandemic on European Capital markets and Capital Market Recovery Package

Finance industry urges nine-month delay for ESG suitability rules

6 Jul 2020
Topic — EU regulation requiring investment firms to integrate sustainability factors into client assessments.
Message — The Associations request a nine-month implementation delay after product governance rules take effect. They argue firms need time to update client profiles and source ESG data, citing significant data availability issues. They also seek clarity that ESG assessments should only apply to products with sustainable objectives.123
Why — This would give them more time to upgrade IT systems and avoid clashing with other 2021 regulatory deadlines.45
Impact — Investors seeking ESG products face continued uncertainty about which investments meet sustainability preferences.6
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Finance industry urges nine-month delay for ESG rules

6 Jul 2020
Topic — EU directive requiring firms to integrate sustainability factors into product governance.
Message — AFME requests a nine-month implementation period after Member States transpose the directive, warning the current timeline could leave firms only one day to comply. They want flexibility to exclude products without sustainability elements and exemption from reviewing pre-existing instruments for ESG factors.1234
Why — This would give them time to upgrade IT systems and avoid costly reviews of existing products.56
Impact — Sustainable investors lose faster access to ESG information about existing financial products.7
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

9 Jun 2020 · Covid-19 economic recovery and Capital markets

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

29 May 2020 · digital finance

Meeting with Jérome Deslandes (Cabinet of Executive Vice-President Valdis Dombrovskis)

4 May 2020 · Capital Requirements Regulation

Financial industry seeks clearer GDPR rules for cross-border data flows

29 Apr 2020
Topic — Review of General Data Protection Regulation implementation, focusing on international transfers and cooperation.
Message — The organization requests broader review beyond international transfers and authority cooperation. They seek clarity on conflicts between GDPR and financial regulations, particularly for anti-money laundering data sharing. They want improved standard contractual clauses for processors transferring data to non-EU sub-processors.1234
Why — This would reduce legal uncertainty and compliance complexity for cross-border financial operations.56
Impact — Data subjects lose if clearer rules facilitate easier transfers without stronger safeguards.7
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

15 Apr 2020 · COVID-19 and Financial Markets, AFME coronavirus initiatives, CSDR buy-ins, MiFID, and CMU/securitisation.

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

3 Apr 2020 · COVID-19 and Financial Markets, MIFID Review, CMU - Securitisation and other AFME priorities

Finance Industry Pushes Public-Private Partnerships for Money Laundering Fight

11 Mar 2020
Topic — EU strategy to strengthen anti-money laundering and counter-terrorism financing regulations.
Message — The association wants stronger public-private partnerships for intelligence sharing and bank-to-bank information exchange. They advocate moving toward maximum harmonization through EU regulations rather than national directives, with uniform Know-Your-Customer requirements across member states.123
Why — This would let banks operate with uniform policies and use resources more efficiently.4
Impact — National regulators lose flexibility to impose stricter money laundering controls than EU baseline.5
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Meeting with Jérome Deslandes (Cabinet of Executive Vice-President Valdis Dombrovskis)

17 Feb 2020 · Presentation of AFME’s position paper on Basel III

Financial markets association challenges auditor requirement removal for profit forecasts

21 Dec 2018
Topic — EU regulation on prospectus format, content, scrutiny and approval for securities offerings.
Message — AFME urges the Commission to reinstate the mandatory auditor report requirement for profit forecasts in prospectuses. They argue removing independent verification may result in less reliable forecasts and auditors becoming reluctant to provide comfort to issuers.123
Why — This would preserve flexibility in disclosure while maintaining rigorous verification for marketing-focused forecasts.45
Impact — The Commission loses simplified prospectus requirements and harmonized scrutiny across member states.6
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Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

20 Nov 2018 · Non-performing loans package

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

15 Nov 2018 · PRIIPs

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

12 Sept 2018 · Securitisation

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

12 Sept 2018 · Post-trade

Financial industry urges gradual taxonomy approach before regulatory changes

22 Aug 2018
Topic — EU regulation establishing criteria for determining which economic activities are environmentally sustainable.
Message — AFME requests the Commission develop the taxonomy before amending other financial regulations like MiFID II. They want clarity that the taxonomy applies to economic activities rather than specific products, and seek flexibility to incorporate existing market frameworks like the Green Bond Principles. They emphasize the need for regular updates and warn against overly prescriptive requirements.123
Why — This would allow banks to avoid applying sustainability criteria across all offerings and maintain existing investment approaches.45
Impact — Investors seeking broader sustainable strategies lose as narrow product scope limits diversification options.67
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Financial Industry Urges EU Adopt Global LEI Over EUID

9 Jul 2018
Topic — EU proposal to digitize company law administrative processes and entity identification.
Message — AFME and ISDA request the Commission replace the proposed EUID with the Legal Entity Identifier (LEI) as the standard identifier for EU companies. They argue the LEI is already a global standard endorsed by the G20, used across EU financial regulations, and would avoid forcing companies to maintain multiple identifiers.123
Why — This would eliminate duplicate compliance requirements for financial firms already using LEIs.45
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

6 Jul 2018 · Prudential Board meeting (on Banking Union and Capital Markets Union)

Response to Safekeeping duties of depositaries for Alternative Investment Funds

26 Jun 2018

Please see our feedback in the attached file. AFME Contact: Gary Simmons
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Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

The Association for Financial Markets in Europe (AFME) is the voice of all Europe’s wholesale financial markets, providing expertise across a broad range of regulatory and capital markets issues. We represent the leading global and European banks and other significant capital market players. We advocate for deep and integrated European capital markets which serve the needs of companies and investors, supporting economic growth and benefiting society. We aim to act as a bridge between market participants and policy makers across Europe, drawing on our strong and long-standing relationships, our technical knowledge and fact-based work. We welcome the Commission’s Action Plan on Sustainable Finance and support the objectives to improve the flow of information so that clients make better informed sustainable investment decisions. Overall, we believe that a workable, flexible and dynamic taxonomy is a pivotal initiative which should be achieved prior to any important review of existing financial regulations, including MiFID II. Detailed comments on the draft amendments to Regulation (EU) 2017/565 supplementing Directive 2014/65/EU are set out in the attached document. We remain at your disposal for discussing the proposal and, for any questions you may have.
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Financial markets lobby warns EU NPL rules risk harming loan trading

8 Jun 2018
Topic — EU directive on credit servicers, purchasers and collateral recovery for non-performing loans.
Message — AFME requests narrower scope excluding performing loans and syndicated arrangements. They want the directive focused only on non-performing loans to avoid disrupting well-functioning markets. They argue the broad scope would impose unnecessary costs and reduce liquidity in performing loan markets.123
Why — This would allow banks to avoid costly new disclosure rules for profitable loan sales.45
Impact — Borrowers lose protections as buyer-beware principle reversal is rejected for performing loans.6
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Intesa Sanpaolo and

6 Jun 2018 · Cyber security, Fintech

Meeting with Julie Ruff (Cabinet of Commissioner Julian King)

6 Jun 2018 · Cybersecurity

Financial markets association urges flexibility on non-performing loan provisions

24 May 2018
Topic — Statutory prudential backstops to prevent under-provisioning of non-performing loans in banks.
Message — AFME opposes the Commission's Pillar 1 approach to non-performing loans, arguing it is inadequate for the heterogenous nature of NPLs. They advocate for a Pillar 2 approach that accounts for banks' specific NPL portfolios and economic environments. They also request alignment between the Commission's proposal and the ECB's guidance to avoid duplicative processes.123
Why — This would reduce compliance costs and avoid operational burden from running duplicative processes.45
Impact — SMEs and corporate clients face higher borrowing costs and reduced lending volumes.6
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Response to Revised calibrations for securitisation investments by insurance and reinsurance undertakings under Solvency II

15 May 2018

AFME welcomes certain aspects of the proposed new draft delegated regulation amending Delegated Regulation (EU) 2015/35 (the “New Solvency II Regime”) as regards the calculation of regulatory capital requirements for securitisations and simple, transparent and standardised (“STS”) securitisations held by insurance and reinsurance undertakings (the “Proposals”). AFME has consistently supported the European Commission’s proposals for a new framework for STS securitisations as well as a new common framework for all securitisations. We strongly support the Commission’s efforts to harmonise existing legislation with the newly-established framework for both STS securitisation (the “STS Framework”) and all securitisations whether STS or not (the “Common Framework”). We are confident that the long-term impact of the new regime can be positive. However, this will only be the case if critical related EU legislation, including these Proposals, are calibrated to create the right conditions and incentives to support the recovery of safe and well-regulated securitisation in Europe as a key pillar of the Capital Markets Union. Unfortunately, while there are positive aspects to the Proposals we believe that overall they do not go far enough in correcting the harsh and disproportionate treatment of securitisation investments under Solvency II. We attach the letter which sets out our concerns in details.
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Financial industry urges deadline flexibility in shareholder rights rules

9 May 2018
Topic — EU regulation on shareholder identification and transmission of information for voting rights.
Message — AFME requests flexible 'without undue delay' language instead of same-day transmission requirements, and opposes extremely tight deadlines for information transfer. They seek alignment with existing market standards and opt-out provisions for shareholders not wishing to receive notifications.123
Why — This would reduce operational complexity and allow time for manual processing requirements.45
Impact — Shareholders lose faster notification of corporate events and voting opportunities.6
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

23 Mar 2018 · PRIIPs, Sustainable finance, ESAs review

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

16 Mar 2018 · LCR and LCR and Solvency II; securitisation

Response to Draft Delegated Act amending the Commission Delegated Regulation on the Liquidity Coverage Ratio ('LCR')

21 Feb 2018

AFME comments both on securitisation aspects and wider prudential aspects of the Commission’s proposals. Securitisation AFME supports in principle the integration into the LCR Delegated Regulation of the new simple, transparent and standardised (“STS”) criteria for securitisation. It is sensible to update and make consistent the existing LCR criteria with the new European securitisation framework. AFME has consistently supported the Commission’s proposals for a new framework for both STS and non-STS securitisations. We are confident that the long-term impact of the new regime can be positive. However, this will only be the case if critical related EU legislation such as the LCR Delegated Regulation is calibrated to create the right conditions and incentives to support the recovery of safe and well-regulated securitisation in Europe as a key pillar of Capital Markets Union. Unfortunately the amendments proposed by the Commission to the LCR Delegated Regulation do not achieve this. Our alternative proposal is summarised below and set out in more detail in our attached letter, together with supporting arguments and evidence. Our proposal for securitisation We propose firstly that all STS securitisations, whether term or ABCP, should be classified as Level 2A assets with maximum allocations and minimum haircuts equivalent to the current treatment of covered bonds of CQS 2. There should be no rating requirement, but only the senior tranche should be eligible. We propose secondly that non-STS securitisations: • which are term securitisations and comply with the requirements of Article 13, or • which are ABCP and are fully-supported (as defined in Regulation 2017/2402), are not re-securitisations and do not include any underlying exposures which are securitisations or synthetic securitisations, should continue to be treated as Level 2B assets with the same maximum allocations and minimum haircuts as apply today save that non-STS ABCP programmes which are fully-supported should receive a minimum haircut of 15%. Wider prudential aspects Please see our attached letter.
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Finance Industry Urges Caution on European Safe Asset Plans

20 Feb 2018
Topic — EU framework for creating sovereign bond-backed securities as European safe assets.
Message — AFME requests further consultations before progressing the initiative, expressing concerns about market feasibility and unintended consequences. They argue essential criteria for success have not been met and warn the proposal could harm European government bond market liquidity.123
Why — This would protect their members' profitable sovereign debt trading operations from disruption.45
Impact — Proponents of Banking Union completion lose momentum toward breaking sovereign-bank doom loop.67
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Response to Review of the European Supervisory Authorities

23 Jan 2018

The Association for Financial Markets in Europe ("AFME") is the voice of all Europe’s wholesale financial markets, providing expertise across a broad range of regulatory and capital markets issues. We represent the leading global and European banks and other significant capital market players. We advocate for deep and integrated European capital markets which serve the needs of companies and investors, supporting economic growth and benefiting society. We aim to act as a bridge between market participants and policy makers across Europe, drawing on our strong and long-standing relationships, our technical knowledge and fact-based work. AFME welcomes the opportunity to provide feedback to the European Commission Proposal for a Regulation on the operation of the European Supervisory Authorities. Please refer to the attached document for AFME's detailed response.
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Financial Markets Group Backs EU Crowdfunding Framework

24 Nov 2017
Topic — European Commission proposal for EU-wide regulation of crowdfunding and peer-to-peer finance platforms.
Message — The association favours options creating an EU-wide framework with adequate oversight of platforms, a European single market for retail investors, and clearer rules using existing passporting regimes to enable cross-border growth.1234
Why — This would help crowdfunding platforms scale cross-border and overcome current legal fragmentation barriers.56
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Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

14 Sept 2017 · CMU and Banking Union

Financial markets lobby opposes systematic internaliser rule changes

13 Jul 2017
Topic — European Commission proposal to tighten rules on systematic internaliser trading activities.
Message — AFME requests amendments to preserve broker-dealer flexibility and intra-group risk management. They argue the current drafting is too broad and could restrict firms from accessing liquidity for clients and managing risk internally.123
Why — This would preserve their ability to manage risk and maintain profitable intra-group arrangements.45
Impact — Market transparency suffers as firms maintain ability to bypass trading venue requirements.6
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and

21 Jun 2017 · first part of the regulatory review, cross-Border regulatory coordination, cyber security, Brexit and its external impacts

Meeting with Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

7 Apr 2017 · Retail banking secor, analysis of the General Data protection regulation (GDPR)

Meeting with Michelle Sutton (Cabinet of First Vice-President Frans Timmermans)

7 Mar 2017 · Better Regulation, Capital Markets Union, Transparency

Meeting with Valdis Dombrovskis (Vice-President) and

7 Mar 2017 · Keynote speech at the Conference on "The Shortage of Risk Capital for Europe's High Growth"

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

3 Feb 2017 · Banking Package; ESA review

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici)

17 Nov 2016 · ‘CRD5’ package

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

9 Nov 2016 · financial services agenda

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

19 Oct 2016 · EU financial services regulation

Meeting with Bodo Lehmann (Digital Economy)

13 Oct 2016 · cybersecurity

Meeting with Bodo Lehmann (Digital Economy)

13 Oct 2016 · cybersecurity

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen) and Citigroup Inc. and HSBC Holdings PLC

22 Sept 2016 · Sustainable finance

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

20 Sept 2016 · Basel

Meeting with Keith Sequeira (Cabinet of Commissioner Carlos Moedas)

5 Jul 2016 · Finance and Innovation

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

18 Apr 2016 · Securitisation; Banking prudential issues;

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

27 Jan 2016 · Capital Markets Union

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

27 Jan 2016 · Investment plan

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

11 Jan 2016 · Joint meeting/Markets in Financial Instruments Directive level2

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

18 Sept 2015 · Securitisation

Meeting with Matthew Baldwin (Cabinet of Commissioner Jonathan Hill)

17 Sept 2015 · Financial Policy

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

17 Jul 2015 · Capital Markets Union

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

16 Apr 2015 · Markets in Financial Instruments Directive

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

10 Apr 2015 · Markets in Financial Instruments Directive

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

27 Mar 2015 · Discussion on the study on the impact of NSFR on capital markets

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen) and European Forum for Manufacturing

18 Mar 2015 · Event preparation

Meeting with Jonathan Hill (Commissioner)

27 Jan 2015 · Capital Markets Union

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici)

21 Jan 2015 · Capital Markets Union, Banking Union issues: exchange of views

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

19 Jan 2015 · Capital Markets Union

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

16 Jan 2015 · Capital Markets Union

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen)

17 Dec 2014 · Capital markets union

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

17 Dec 2014 · CMU

Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill) and PwCIL

3 Dec 2014 · Bank structural reform