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Associazione Bancaria Italiana

ABI

The Italian Banking Association represents banks and the financial system, promoting competitive markets and defending common interests of banking, leasing, factoring, securities firms and asset managers.

Lobbying Activity

Meeting with Stefano Bonaccini (Member of the European Parliament)

2 Dec 2025 · Meeting with ABI President

Meeting with Pasquale Tridico (Member of the European Parliament, Shadow rapporteur)

2 Dec 2025 · DIGITALEURO

Meeting with Gaetano Pedulla' (Member of the European Parliament)

2 Dec 2025 · Digital euro

Meeting with Ralf Seekatz (Member of the European Parliament, Rapporteur)

1 Dec 2025 · Verbriefung

Meeting with Marco Falcone (Member of the European Parliament)

11 Nov 2025 · Establishment of the digital euro

Meeting with Giovanni Crosetto (Member of the European Parliament, Shadow rapporteur) and Fédération bancaire française and

5 Nov 2025 · Securitisation Framework

Meeting with Maria Luís Albuquerque (Commissioner) and

23 Oct 2025 · SIU, FIDA

Meeting with Giovanni Crosetto (Member of the European Parliament, Shadow rapporteur)

2 Oct 2025 · Securitisation Framework

Meeting with Valdis Dombrovskis (Commissioner) and

5 Sept 2025 · SIMPLIFICATION

Response to Heavy Duty Vehicles CO2 and fuel consumption certification

14 Jul 2025

Securitisation can allow banks to strengthen and increase their capability to provide more lending to the real economy, enabling them to free up regulatory capital which can be used to originate new loans, and it can contribute to a well-diversifying funding source. In the last years, the impediments for originators and investors to securitise and invest in securitisations have been represented by the excessive regulations and high capital requirements, which have created high transaction costs and barriers to entry in the securitisation market; these regulatory impediments affect all securitisations (for example, securitisations of SMEs, corporate, consumer, mortgage or auto loans). In addition to the high implementation costs and capital requirements, another main aspect of the regulation that limits the investments in securitisations is represented by the current treatment of securitisation in the liquidity coverage ratio (LCR treatment), which is too restrictive, and it does not reflect the actual characteristics of securitisations. As a result, many players have preferred to invest in other types of products. The European commission proposal amending Delegated Regulation (EU) 2015/61, as regards the eligibility conditions for securitisations in the liquidity buffer of credit institutions, provides some improvements (such as the removal of the WAL limitation and the increase of the eligibility to those positions with credit quality from step 1 to step 7). However, more adjustments would be necessary to make securitisation more appealing for banks and investors, increasing the market liquidity. In particular, the classification proposed for the eligibility of the securitisation in the liquidity buffer i.e. Level 2B for senior tranche of STS traditional securitisation - and the not eligibility for those non-STS, do not fully reflect securitisation assets sound liquidity profiles. It should be recalled that securitisation trades actively and maintains relatively stable prices also during increased volatility. In this regard, with aim to support the EU securitisation market, the eligibility of securitisations in the liquidity buffer should be improved, allowing senior STS tranches (both resilient and non-resilient securitisation positions under the legislative proposal of the European commission of the last 17 June) to be treated as Level 2A. Moreover, it would be necessary to make eligible in the liquidity buffer as Level 2A also those senior non-STS securitisations resilient positions, considering their high-quality, with an opportune adjustment of the haircuts to apply. The senior non-STS securitisations non-resilient positions should be recognised as eligible assets for Level 2B.
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ABI Urges Flexible, Market-Driven European Investment Account Framework

7 Jul 2025
Topic — This initiative proposes a European blueprint for savings and investment account best practices.
Message — ABI calls for a flexible framework using broad wrappers and avoiding new distribution rules. They advocate for simplified MiFID disclosures and tax incentives to reward long-term holdings.12
Why — This approach protects existing bank products and minimizes new regulatory compliance burdens.3
Impact — Retail investors may receive less detailed information due to reduced disclosure requirements.4
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Meeting with Irene Tinagli (Member of the European Parliament)

4 Jun 2025 · Courtesy meeting

Meeting with Marco Falcone (Member of the European Parliament)

3 Jun 2025 · Riflessioni dal mondo bancario sui principali dossier di materia finanziaria in esame al Parlamento europeo

Italian Banking Association urges simplified sustainable finance disclosures

29 May 2025
Topic — European officials are revising regulations to simplify sustainable finance reporting and disclosures.
Message — The association requests simplifying product disclosures to focus on key sustainability features. They suggest deleting burdensome entity-level impact statements and creating a transition finance category.123
Why — Streamlined requirements would lower administrative costs and protect previous technical infrastructure investments.45
Impact — Public transparency may decline if website disclosures are limited to standard periodic reports.6
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Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur) and Deutsche Bank AG and

30 Apr 2025 · AI in Financial Services

Meeting with Giovanni Crosetto (Member of the European Parliament, Shadow rapporteur)

18 Mar 2025 · Capital Market Union

Response to Savings and Investments Union

6 Mar 2025

The 2020 CMU Action Plan has only partially achieved its objectives: some initiatives have not been completed and others have not yet produced the expected results. This is because these were mainly legislative or regulatory actions, which require lengthy processes for their definition and approval. Relatively little has been done to support long-term investments and the process of removing national barriers that make the process of integration into a true single European market difficult. In this complex scenario, it becomes fundamental to position the proposals and actions for the relaunch of the Capital Markets Union within a new comprehensive vision that involves all key institutions and actors, both at the European and national levels. A significant effort that should also lead to link the Banking Union with the Capital Markets Union, with simple solutions, removing barriers at both the EU and national levels, checking the coherence of the entire regulatory framework (pension funds, insurance, etc.) in order to increase the participation of retail investors in financial markets. An integrated, efficient and liquid European capital market must therefore be a founding pillar of the European Union's overall strategy for the coming years. The role of banks is fundamental for the Capital Markets and they can be a lever for accelerating the implementation of the Capital Markets Union. Banks are, first and foremost, issuers and investment product manufacturer. They also act as intermediaries, helping companies access the capital market. Banking and capital markets activity are complementary and mutually reinforcing. We, therefore, support the proposal to address such issues through a new project, the Savings and Investments Union (SIU), that might effectively connect the buy side with the sell side of the financial market, benefiting both European citizens as investors and European corporates and enterprises, which demand capital for growing, innovating and becoming more competitive and foster the development of capital and banking markets. We then look forward to the publication of the Communication containing the Commissions strategy for the SIU. Regarding the current preliminary call for evidence: - we share the four areas where the Commission intends to envisage a number of hopefully impactful measures. They are in line with our idea that the right way to identify the proposals and actions is to look at the three fundamental components of the capital market: supply and demand of capital, market infrastructures and rules and supervision. We are pleased to offer some initial thoughts in the following part of this paper. - we welcome the decision of the Commission to ensure the right balance between legislative or non-legislative action, acknowledging that legislative action should be focused on key areas and reduce burdens as much as possible. However, we believe that it is of outmost importance that any regulatory or legislative proposal would be accompanied by a true impact assessment of costs and benefits of any action. In this direction goes the commitment of the Commission to conduct such assessment for the individual legislative actions and other initiatives that will be announced in the Communication, that we hope will not remain unheard. - we urge the Commission to consider simplifying the current capital markets regulatory environment instead of adding new legislation, requirements and constrains, as it was unfortunately done for some actions of the 2020 CMU Action Plan (i.e. RIS). Please find in the attached position paper our specific remarks and proposals regarding the four area of intervention.
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

6 Mar 2025 · Competitiveness

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

6 Mar 2025 · Exchange of views on banking matters in the context of the Savings and Investment Union

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 Antonio Decaro (Member of the European Parliament)

28 Jan 2025 · Meeting con Presidente Associazione Bancaria Italiana

Meeting with Raffaele Fitto (Executive Vice-President)

28 Jan 2025 · Exchange of views on the current challenges for the banking sector within the EU framework

Meeting with Herbert Dorfmann (Member of the European Parliament)

28 Jan 2025 · The future of the banking sector in the EU

Meeting with Stefano Bonaccini (Member of the European Parliament)

28 Jan 2025 · Meeting with Associazione Bancaria Italiana

Meeting with Antonella Sberna (Member of the European Parliament)

28 Jan 2025 · Il ruolo delle banche italiane nella competitività e sostenibilità del sistema finanziario europeo

Meeting with Carlo Fidanza (Member of the European Parliament) and Istituto per la Competitività and ASSOGAS Associazione Nazionale Industriali Privati Gas e Servizi Energetici

28 Jan 2025 · Introductory Meeting

Meeting with Leoluca Orlando (Member of the European Parliament)

28 Jan 2025 · meeting with representative of ABI (Associazione Bancaria Italiana)

Meeting with Pasquale Tridico (Member of the European Parliament)

28 Jan 2025 · Meeting with ABI - Antonio Patuelli

Italian banks urge flexibility in voluntary green bond reporting

27 Jan 2025
Topic — A consultation on voluntary disclosure templates for green and sustainability-linked bonds.
Message — The association recommends updating bond terminology and including a wider range of activities. They also propose using broad summaries for large portfolios rather than specific project data.123
Why — This would allow banks to use standardized reporting while maintaining market preferences.4
Impact — Transparency could decrease for investors seeking specific details on individual green projects.5
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Meeting with Irene Tinagli (Member of the European Parliament) and FEDERCASSE - Federazione Italiana delle Banche di Credito Cooperativo Casse Rurali e Artigiane

10 Sept 2024 · Meeting on Banking Issues

Meeting with Gaetano Pedulla' (Member of the European Parliament)

23 Jul 2024 · Dati e trends del settore bancario italiano

Meeting with Marco Zanni (Member of the European Parliament)

9 Apr 2024 · Banking issues

Meeting with Fabio Massimo Castaldo (Member of the European Parliament)

14 Feb 2024 · Establishment of the digital euro

Meeting with Paolo Gentiloni (Commissioner)

24 Jan 2024 · Exchange of views on how banks can contribute to growth and European economic priorities

Meeting with Fulvio Martusciello (Member of the European Parliament)

23 Jan 2024 · Exchange of views with ABI representatives in view of the upcoming legislature

Meeting with Pina Picierno (Member of the European Parliament)

30 Nov 2023 · General discussion on European policies

Meeting with Antonio Maria Rinaldi (Member of the European Parliament)

28 Nov 2023 · ECON

Italian Banking Association Urges Gradual Rollout of Open Finance Rules

31 Oct 2023
Topic — This consultation seeks feedback on the proposed EU framework for financial data access.
Message — ABI recommends a staggered approach to data sharing to protect customer interests. They request a narrower data scope that excludes trade secrets and processed data. The association also demands equal access rules to prevent unfair competition from non-EU providers.123
Why — Stricter rules would prevent Big Tech from gaining a dominant position using bank data.4
Impact — Non-financial tech companies would face stricter barriers and limited access to bank data.5
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Response to Payment services – revision of EU rules (Directive)

31 Oct 2023

We welcome the choice of a Regulation for the provisions on the scope of payment services (PSs), transparency and rights and obligations as it goes in the direction to create a uniform EU regulatory framework avoid fragmentation and competitive disparities. We agree that the proposals entail an evolution of the payment sector leveraging the investment already made (e.g.PSD2 dedicated interfaces). The PSD2/EMD merger is also welcomed as it brings greater simplification of transparency requirements. Nevertheless, some points must be clarified: --Open Banking (OB): - Dedicated interfaces: we appreciate the removal of the fallback exemption obligation, but we believe the requirements on alternative solutions effectively re-propose the provision of a permanent fallback and as such should be eliminated to avoid new compliance costs for PSPs - Compensation: PSD2 fostered the development of new PSs (AIS/PIS), which required implementation costs disproportionate to the effective/real benefits. The desired level playing field should be ensured in view of the future development of OB by introducing in PSR a possibility for compensation in line with FIDA/Data Act --Frauds: - Liabilities extension to all relevant actors: we consider worrying and inadequate the exclusion from PSR (see Art 59) of market players that provide support to the provision of PSs (e.g. TELCOs), which sometimes interact directly with end users and allow PSPs to integrate their payment solutions on a single interface. We believe these providers should be subject to the regulatory provisions relating to fraud (e.g.impersonation fraud), the process of recovery of fraudulent amounts and the associated liabilities. The close cooperation currently provided for is not sufficient to ensure the overall security of PSs/users - Targeted measures: although SCA has proven to be an effective measure to mitigate and in some cases counteract frauds, the emerging of new types of fraud (e.g.social engineering) requires a process that enables PSPs to certify that it is an actual fraud and recover funds. The current regulatory framework still lacks as to how to determine situations in which payer-side fraud occurs as well as the process of collaboration/information exchange with the payees PSP to recover fraudulent amounts and allocate related liabilities - Users awareness and refund: a general refund obligation for PSPs for impersonation fraud would run counter to EU efforts to ensure accessible payment transactions, would increase scams and negatively affect overall payments security. We highlight the lack of a clear repartition of liabilities between PSPs and users, due to the absence of a definition of gross negligence in a uniform manner across countries and the associated liabilities. It could be beneficial to clarify at EU level the parameters for gross negligence cases and introduce criteria to assess the level of carelessness in relation to payments processes --Timeframes and transposition rules: we emphasize the importance of reasonable timelines (e.g.RTS/GL development) and careful consideration of transition rules to avoid continuous updating as met in PSD2 --Coordination with other regulatory acts: coordination is needed with other EU laws (e.g.MICAR, Digital , eIDAS/EUID, Accessibility Act, Instant Payments, Data Act, etc) As far as PSD3 is concerned, further reflection on the possible impacts of separate provisions on licensing and supervision is needed. We are specifically concerned about potential misalignment stemming from different timelines for transposition and implementations. ASPSP may be dealing with third parties authorized/registered under PSD2 but no more compliant with the PSRs rules (immediately applicable) until a renewal of authorization/registration occurs (requiring national transposition). The interim period should be explored more in terms of market impacts. Specific comments on the main articles and typos are highlighted in the attached document
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Response to Payment services – revision of EU rules (new Regulation)

31 Oct 2023

We welcome the choice of a Regulation for the provisions on the scope of payment services (PSs), transparency and rights and obligations as it goes in the direction to create a uniform EU regulatory framework avoid fragmentation and competitive disparities. We agree that the proposals entail an evolution of the payment sector leveraging the investment already made (e.g.PSD2 dedicated interfaces). The PSD2/EMD merger is also welcomed as it brings greater simplification of transparency requirements. Nevertheless, some points must be clarified: --Open Banking (OB): - Dedicated interfaces: we appreciate the removal of the fallback exemption obligation, but we believe the requirements on alternative solutions effectively re-propose the provision of a permanent fallback and as such should be eliminated to avoid new compliance costs for PSPs - Compensation: PSD2 fostered the development of new PSs (AIS/PIS), which required implementation costs disproportionate to the effective/real benefits. The desired level playing field should be ensured in view of the future development of OB by introducing in PSR a possibility for compensation in line with FIDA/Data Act --Frauds: - Liabilities extension to all relevant actors: we consider worrying and inadequate the exclusion from PSR (see Art 59) of market players that provide support to the provision of PSs (e.g. TELCOs), which sometimes interact directly with end users and allow PSPs to integrate their payment solutions on a single interface. We believe these providers should be subject to the regulatory provisions relating to fraud (e.g.impersonation fraud), the process of recovery of fraudulent amounts and the associated liabilities. The close cooperation currently provided for is not sufficient to ensure the overall security of PSs/users - Targeted measures: although SCA has proven to be an effective measure to mitigate and in some cases counteract frauds, the emerging of new types of fraud (e.g.social engineering) requires a process that enables PSPs to certify that it is an actual fraud and recover funds. The current regulatory framework still lacks as to how to determine situations in which payer-side fraud occurs as well as the process of collaboration/information exchange with the payees PSP to recover fraudulent amounts and allocate related liabilities - Users awareness and refund: a general refund obligation for PSPs for impersonation fraud would run counter to EU efforts to ensure accessible payment transactions, would increase scams and negatively affect overall payments security. We highlight the lack of a clear repartition of liabilities between PSPs and users, due to the absence of a definition of gross negligence in a uniform manner across countries and the associated liabilities. It could be beneficial to clarify at EU level the parameters for gross negligence cases and introduce criteria to assess the level of carelessness in relation to payments processes --Timeframes and transposition rules: we emphasize the importance of reasonable timelines (e.g.RTS/GL development) and careful consideration of transition rules to avoid continuous updating as met in PSD2 --Coordination with other regulatory acts: coordination is needed with other EU laws (e.g.MICAR, Digital , eIDAS/EUID, Accessibility Act, Instant Payments, Data Act, etc) As far as PSD3 is concerned, further reflection on the possible impacts of separate provisions on licensing and supervision is needed. We are specifically concerned about potential misalignment stemming from different timelines for transposition and implementations. ASPSP may be dealing with third parties authorized/registered under PSD2 but no more compliant with the PSRs rules (immediately applicable) until a renewal of authorization/registration occurs (requiring national transposition). The interim period should be explored more in terms of market impacts. Specific comments on the main articles and typos are highlighted in the attached document
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Meeting with Marco Zanni (Member of the European Parliament, Shadow rapporteur)

20 Sept 2023 · Banking issues

Italian Banking Association urges clearer definitions and implementation delays

18 Sept 2023
Topic — The European Commission proposes a standardized EU system for withholding tax relief.
Message — ABI requests a precise beneficial owner definition and voluntary registration for intermediaries. They also advocate for an eighteen-month delay following national transposition.123
Why — These changes would lower administrative costs and prevent burdensome compulsory reporting requirements.4
Impact — Small investors may lose access to services if banks withdraw from markets.5
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Response to Establishing the digital euro

8 Sept 2023

Compensation/business model. While it is acknowledged that certain fundamental services must be provided to end-users without charges to ensure widespread adoption, it is imperative to facilitate the development of robust business models for intermediaries. This should rely on: a) a more sustainable compensation model, not only based on transaction fees, but also considering infrastructure investments, account setup and management, lost revenues, and opportunity costs; b) the possibility to develop value-added services based on the innovative characteristics of the digital euro (D). Limits and basic use. To preserve financial stability, the D is not to be used as a store of value, but only as a means of payment. The application of limits on D holdings, both for online and offline modes, is the best way to prevent excessive use of the D. Moreover, for the D not to crowd out existing payment means (nullifying the investments already made and those in progress), it is important to set limits on the amount of a single transaction and on the number and total amount of transactions in a defined timeframe to be included in the basic use, free of charge. Beyond these constraints, the user will activate a value-added service, whose price will be set by market forces. For this reason, the list of basic services should be revised, particularly for non-consumers and offline use, also circumscribing the number of services which are to be offered with no charge. As an example, free unlimited (de)funding mechanisms could incentivise uneconomical behaviour by users, as well as uncapped reverse waterfall would incentivise high value payments moving from CoBM credit transfers to the D, thus increasing potential impacts on PSPs liquidity and overall payment profitability. Innovative added-value. To concretely achieve the ECB original goals, such as strategic autonomy, monetary sovereignty, and innovation, it is not possible for the D to merely replicate services that are already available through other payment instruments, but it is necessary to build the D to enable new ones: the D must act as a raw material to accelerate the European digital economy, including programmability functions. In this way, it will be able to constitute a sufficiently attractive proposition for users, so as to ensure the minimum adoption that will enable the achievement of the objectives. The Regulation should be more explicit on this. Offline. Offline is conceived as a further version of the D, with separate infrastructures, an ad hoc balance, and no visibility for intermediaries. Should these hypotheses be confirmed, we would note important critical issues. First, such an offline component generates only few benefits that cannot offset the high implementation costs and the time-consuming development. Moreover, for compliance with AML/CFT rules, PSPs need to have visibility on the information on the payee/payer. Also, since fraud prevention systems are fed by all transaction data, they need data also from offline transactions (that by the way, based on the experience of the card market, are the most prone to fraudulent use). So, dual offline functionalities (when both the user and the PoI are without connection) should be conceived only as a backup, strictly limited in time. Multiple accounts. The regulation enables natural persons to open an endless number of D accounts with different PSPs. While recognizing a potential benefit in terms of contestability in the market, multiple accounts may compromise the respect of the threshold of D holdings, potentially causing serious risks of bank disintermediation. Moreover, it is unclear how to ensure the respect of limits over time, when it is left to the final user to set and distribute them potentially across multiple distributors. This approach will increase complexity also for users. For these reasons, at least for an initial stage, we strongly recommend enabling natural persons to open only one wallet.
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

29 Aug 2023

ABI welcomes the Commissions effort to optimize the Crisis Management and Deposit Insurance framework by amending three legislative texts, namely the Banking Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism regulation (SRMR) and the Deposit Guarantee Schemes Directive (DGSD). The complexity of the regulatory intervention - which tackles strategic profiles of the Banking Union - was recently remarked by the Association in a letter to the EU Commission, together with a first evaluation of the proposals. In her reply, Commissioner McGuinness gave some preliminary clarifications regarding the objectives of the proposals, which will be duly considered in the following remarks. At the same time, in our opinion, those same clarifications we received show that the legislative texts, per se, are not yet sufficiently clear in some crucial parts, faced with a fundamental need for certainty of rules and consequent predictability in their application and outcomes. Therefore, we believe that the EC proposals may be further improved, in order to pursue and achieve the common interest of financial stability of the banking sector while, at the same time, safeguarding competition among market players with the minimum burden on taxpayers. In particular, ABI believes that adjustments may be made, as described in the attached file.
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

29 Aug 2023

Italian Banking Association (ABI) welcomes the Commissions effort to optimize the Crisis Management and Deposit Insurance framework by amending three legislative texts, namely the Banking Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism regulation (SRMR) and the Deposit Guarantee Schemes Directive (DGSD). The complexity of the regulatory intervention - which tackles strategic profiles of the Banking Union - was recently remarked by the Association in a letter to the EU Commission, together with a first evaluation of the proposals. In her reply, Commissioner McGuinness gave some preliminary clarifications regarding the objectives of the proposals, which will be duly considered in the following remarks. At the same time, in our opinion, those same clarifications we received show that the legislative texts, per se, are not yet sufficiently clear in some crucial parts, faced with a fundamental need for certainty of rules and consequent predictability in their application and outcomes. Therefore, we believe that the EC proposals may be further improved, in order to pursue and achieve the common interest of financial stability of the banking sector while, at the same time, safeguarding competition among market players with the minimum burden on taxpayers. In particular, ABI believes that adjustments may be made, as described in the attached file.
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Italian Banking Association warns EU rules prioritize cost over quality

9 Aug 2023
Topic — The consultation gathers feedback on proposed EU rules to modernize retail investment protections.
Message — ABI calls for a longer implementation period and a focus on service quality over price. They recommend removing price benchmarks and revising the new 'best interest test' for advisors.12
Why — Banks would avoid price regulation and the high costs of updating complex technical systems.34
Impact — Retail investors lose guaranteed access to the cheapest products through mandatory cost-efficiency comparisons.5
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Meeting with Nicola Danti (Member of the European Parliament)

18 Jul 2023 · Dossier di interesse per ABI

Meeting with Brando Benifei (Member of the European Parliament, Rapporteur)

24 May 2023 · Discussion on the AI Act (held by the Assistant responsible)

Meeting with Irene Tinagli (Member of the European Parliament, Committee chair)

19 Apr 2023 · Participation in the Executive Board

Response to VAT in the Digital Age

27 Mar 2023

See the file attached
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Response to Facilitating small and medium sized enterprises’ access to capital

27 Mar 2023

Multiple-vote share structures represent a mechanism to allow companies owners to retain decision-making powers in a company while raising funds on public markets and, thus, make the process of accessing the European capital markets by small enterprises and entrepreneurs more acceptable as the ownership structure is not diluted. However, the proposal requires member states to ensure that companies may adopt multiple-vote share structures only when they first seek admission to trading on an SME growth market. Member states are then allowed to adopt or maintain national provisions allowing companies to adopt multiple-vote share structures in situations not covered by the Directive. The Commissions choice to opt for a minimum harmonisation directive raises concerns as it doesnt overcome the fragmentation highlighted by the European Commission itself in the explanatory memorandum accompanying the proposal for a directive. The main consequence of this minimum harmonization approach is the different treatment of shareholders of companies by different member states and the competition between different national legal frameworks based on multiple-vote share structures that are more advantageous than others. If national differences to multiple-vote shares structure persist, banks and intermediaries operating in the intermediary chain will face operational difficulties to manage the information flows required to allow the exercise of rights (especially voting rights) associated with the ownership of multiple-vote shares. The experience of those member States where multiple voting rights is already in place is worth mentioning. In the Italian market issuers have been allowed to issue loyalty shares since 2014 and operational problems for intermediaries emerged, especially on a cross-border basis, also due to the lack of specific market standards for the management of corporate events related to multiple voting shares, which to date have not yet been defined. It would therefore be appropriate to ensure a homogeneous approach in terms of both the multiple voting share structures that member states may adopt and the balance between economic rights of shares and voting power that such structures may bring about.
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Response to Facilitating small and medium sized enterprises’ access to capital

27 Mar 2023

The investment research unbundling rule, early introduced under MIFID II and then amended by the CMRP, has not contributed to the growth and the improvement of investment research and, de facto, has not achieved at all the objectives they were originally designed to pursue. Several surveys as well as anecdotal evidence of market participants show, in fact, that the SME coverage has significantly shrunk or even disappeared altogether in the years after the unbundling rule took effect. The consequence was further concentration in the unbundled research market, with significant harm for many local brokers and a reduction in the diversity and breadth/coverage of the research offered. Even the exemption introduced by CMRP in 2021 did not have any concrete effect in alleviating the impact of the MIFID 2 unbundling rule: introducing two parallel procedures for research invoicing (with and without joint payment) has been considered too burdensome. Amendments to Article 24.3 positively redefine the main requirements of investment research and issuer-sponsored research. However, we suggest some further proposal with the aim to increase investment research coverage and drive more investors and market liquidity towards listed companies, especially SMEs. As far as the amendment proposal increasing the threshold of companies market capitalisation to EUR 10 billion, below which the unbundling rules do not apply (Art. 24. 9.c), we believe that it represents a first positive development of the current regime albeit unable to effectively solve the issues. We still consider that the dual invoice mechanism introduced by the CMRP (due to the option to jointly pay for the provision of execution services and the provision of research) is too burdensome. Paradoxically it may seem, as a consequence of the proposed increase of the threshold for exemption to EUR 10 billion, the costs/benefit ratio of such the dual mechanism is likely to lean even more towards the former, as a consequence of the reduced scope and number of above-the-threshold issuers. As already highlighted in the past, the requirements provided to exercise the option are in some cases too complex to be applied in practice and even unclear. In conclusion, we consider that the unbundling rule should be eliminated permanently and joint payment of the research should be allowed with reference to all issuers, regardless of market capitalization. As far as the proposed code of conduct is concerned, that indeed marks a positive step in the context of a sound regulation of the issuer-sponsored research, in order to gather the largest representation of research providers, we propose that it be developed by the industry (or its trade association) and endorsed by a market operator or a competent authority. Finally, we also believe that concrete incentives, such as subsidies and tax incentives, would be needed to revitalize the investment research. Regarding the proposal of a minimum requirement of 10% of the shares subscribed and admitted on trading on regulated markets that should be held by the public (art 51 a. 4), we believe that the setting of such threshold should be delegated to the market operator, as it depends on the market segment and the type of investors acting into the market (large institutional investors vs retail investors).
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Response to Facilitating small and medium sized enterprises’ access to capital

27 Mar 2023

ABI supports the aim of the CMU Action Plan to foster the use of capital markets by European companies as well as the efforts to simplify the EU listing regulatory framework. An effective alleviation of the listing and the post-listing obligations is definitely needed, as well as a reduction of the costs for the issuers. Such alleviation, however, should not prevent an in-deep due diligence activity on equity prospectuses carried on by different advisors aimed at providing the investors with the highest possible standard of information. Indeed such due diligence could be harmed by setting a 300 hundred page limit to the IPO prospectuses. Furthermore, we believe that shrinking the content of the prospectus may expose the issuer and any other liable person to litigation for omitted information, especially in those countries where the prospectus liability regime is more pervasive than the regime contained in the European legislation. The introduction of an overall limit to the length of the IPO prospectus should, therefore, be provided only as a general recommendation not as a binding rule, in order to ensure to each issuer a degree of flexibility in assessing the most appropriate content and length of the prospectus specifying the reasons of this choice in the prospectus. As far as the EU Follow-On Prospectus is concerned, we recognize that the proposed exemptions to publish a prospectus for the offers of fungible securities already admitted to trading significantly ease the access to the market but we consider unlike that different advisors involved in these transactions are able to carry on a deep due diligence process for the investors relying only on a 10 page document, containing the information set out in Annex IX to the proposed regulation. This seems even more unlikely in the case of issuers with recapitalization needs, which, as known, may be commonplace in such transactions. Thus, we consider that in case of issuers not involved in recapitalization needs the 10 page limit document should be implemented at least with a set of minimum information. Flexibility should also be allowed to the issuers to implement the disclosure of information when it is needed, also considering that retail investors are usually and largely involved in secondary issuances transactions. Lastly, it is worthwhile to point out that issuers and investors responding to the previous consultation had expressed their agreement on the streamlining of the prospectus rather than on the introduction of a page limit. We also suggest to introduce a definition of Small and Medium Capitalisation Companies (SMC), in the European financial services legislation, targeting SMEs with a market capitalization of less than 1 billion euros and replacing the various different definitions currently existing also and in the EU Risk Finance Guidelines. We also consider that there is a need to reduce the burdensome provisions of the MAR. The changes proposed by the Commission in the draft regulation go in such direction. However, it is crucial to tackle the problem of when the information becomes inside information and to reduce the risk of publishing information which is not yet mature enough. Although it would be preferable to directly amend the definition of inside information, the choice to narrow down the scope of the obligation to disclose inside information and enhance legal clarity as to what information needs to be disclosed and when, is an important first step forward. Clarifying the safe-harbor nature of the market sounding procedure and simplifying the insider lists regime for all issuers, as proposed, is very useful. Finally, we believe that raising the threshold above which managers shall notify their transactions and expanding the scope of exempted transactions during the so called close period is a very useful simplification. Please see in the attached document specific comments and proposal to the amendments set forth by the European Commission.
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Italian Banking Association calls for narrower scope on clearing rules

21 Mar 2023
Topic — Proposed amendments to EU rules governing central counterparties and derivative clearing markets.
Message — The association requests exempting firms with no third-country positions from active account requirements and limiting rules to new contracts only. They also oppose new reporting burdens and suggest longer transition periods for non-financial firms to arrange collateral.1234
Why — These changes would prevent unnecessary operational costs and avoid forced, expensive migrations of existing portfolios.56
Impact — EU central counterparties lose guaranteed market share if existing third-country contracts are not forced to migrate.78
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

10 Mar 2023 · eID

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

9 Mar 2023 · Retail investment strategy

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

9 Mar 2023 · Retail Investment Strategy

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

22 Feb 2023 · CMDI

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and

1 Feb 2023 · retail investment strategy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness) and Banco Santander, S.A. and

1 Feb 2023 · Retail Investment Strategy

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

1 Feb 2023 · Basel III and Bank crisis management

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

31 Jan 2023 · general discussion on the economic situation and the war in Ukraine (with Erik Burckhardt)

Meeting with Pina Picierno (Member of the European Parliament)

26 Oct 2022 · General discussion European policies

Meeting with Paolo Gentiloni (Commissioner)

25 Oct 2022 · Exchange on the impact of the energy crisis on the banking sector and on the economic outlook

Meeting with Alessandra Basso (Member of the European Parliament, Shadow rapporteur)

25 Oct 2022 · CCD

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and European Banking Federation and BANCO BILBAO VIZCAYA ARGENTARIA

21 Oct 2022 · Digital Euro

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and European Banking Federation and

21 Oct 2022 · digital euro

Response to Review of EU rules on payment services

1 Aug 2022

Since the beginning of 2022, the Italian Banking Association (ABI) started an in-depth analysis in view of a possible revision of PSD2, with the support of the appropriate Members’ Working Groups and coordinating with the European Banking Federation (FBE). As a result of the analyses, the ABI produced a Position Paper aimed at representing the industry’s response to the “call for evidence” which is attached here and whose main points are the following. Of the four options proposed by the European Commission in the “call for evidence” in the event of a PSD2 revision, we favor the following alternative way forward: Focused legislative amendments could primarily clarify existing rules and individual legal concepts across PSD2 as well as including the rules contained into the E-Money Directive. In parallel, the Commission would continue to engage with the national authorities in charge to coordinate enforcing the PSD2, encourage compliance and raise awareness (e.g. of the availability of new payment services and payment products). We summarize here the key aspects included in the above-mentioned ABI Position Paper referring to the different Titles of PSD2. Title I: The scope of the PSD2 should remain as it is, except the current full exclusion from the PSD2 scope of new market actors that somewhat interact into the provision of payment services that should be reviewed in order for these actors to be included/subject to the appropriate provisions. Also some definition and exclusion at articles 3 and 4 should be included. Title II: More should be done on ensuring level playing field among all PSPs. Title III: Simplification and cost reduction for PSPs is a must in case of a PSD2 review as well as harmonization with other regulatory acts (e.g. PAD, Cross-border payments Regulation, etc.). Title IV: Enhancements have to be carried out at least with regard to liabilities (also in consideration of all the actors involved in the full payment chain) and funds recovery processes (art. 73 and 74). Rights and obligations for PSPs should be revisited and at a minimum clarified in the following provisions: a) Open API infrastructure and its functioning (articles 65-67); b) Consent and withdrawal of consent (art. 64) and relation with art.94. Some other elements could be mentioned instead of being completely outside PSD2: a) requirements for standard and common criteria that could allow the market to develop detailed technical standards of implementations and guarantee a more uniform behavior of the involved players; b) PSPs registration processes and clear legal validity of the EBA register. This creates friction in the access to APIs documentation and development; c) Security mechanism to check/monitor/register accesses and transactions along the E2E payment chain; d) Outsourcing arrangements references. Some provisions should be included to facilitate compliance of extra-EEA schemes offering services in EU to European regulations. Title V: Pillars for a possible review are: stability, certainty and uniformity of regulatory requirements to be implemented and deployed according to clear and harmonized adoption timelines. Title VI: Need to foster harmonization of rules and to better envisage the review clause to avoid respectively a different adoption of provision and to ensure proper forecasting of the overall framework timeline in a way that updates are synchronized and overlaps avoided (e.g., RTS proposal to change 90-days SCA). Annex I - Payment services: The payment services listed below should be added to the list in Annex I: a) Issuance of e-money; b) Payment transactions using crypto assets (incl. stable coins); c) Digital wallet services (e.g. mobile apps for payments); d) Payment processing services; e) Operating payment Schemes; f) Other/specific services in the payment chain provided by a technical service provider. We also suggest the merger of PSD2 and the Electronic Money Directive (EMD2).
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Italian Banking Association Urges Withdrawal of EU Tax Proposal

29 Jul 2022
Topic — The proposal creates a tax allowance for equity to reduce corporate debt bias.
Message — The association argues the proposal should be shelved to avoid raising borrowing costs. They also request that banks be included in the new tax allowance for equity.12
Why — Including banks in equity incentives would lower their capital costs and improve loan pricing.3
Impact — European businesses would face higher borrowing costs and more administrative complexity under the proposal.4
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Response to Review of the de minimis aid Regulation

25 Jul 2022

The attached document contains the position of the Italian Multi-stakeholder Working Group on International Regulatory Initiatives, established in Italy in 2019. The following Associations are members of the above Working Group: Associazione Bancaria Italiana, Confindustria, Alleanza delle Cooperative Italiane (AGCI, Confcooperative, Legacoop), CIA Agricoltori Italiani, Confederazione Libere Associazioni Artigiane Italiane, Coldiretti, Confagricoltura, Confapi, Confedilizia, Confetra, Confimi Industria, Copagri, Casartigiani, CNA - Confederazione Nazionale dell’Artigianato e della Piccola e Media Impresa, Confartigianato, Confcommercio and Confesercenti.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

15 Jun 2022 · Proportionality in bank regulation

Meeting with Paolo Gentiloni (Commissioner)

30 May 2022 · Participation in the ABI (Italian banks Association) executive committee meeting – speech about the macroeconomic situation and impact of war, sanctions and the policy response by the European Union, with a focus on Italy.

Response to Central securities depositories – review of EU rules

26 May 2022

In terms of entities subject to the settlement penalties, as we elaborated in our Response to the Commissions’ consultation on a Possible Review of the CSDR (run between December 2020 and February 2021), we continue to suggest the removal of CCPs’ responsibility on the collection and distribution of penalties to clearing members affected by the settlement fails, moving this responsibility on CSDs for both cleared and uncleared transactions. This could be achieved by amending Art. 19 of Delegated Regulation UE 2018/1229. Despite the relevant procedures are now in place at CCPs (complying with the current legislative framework), the current process of collection and redistribution is complex for all the parties involved and a simplification would be very welcome as it would contribute reducing the room for operational issues and reconciliations (which our members continue to mention). As it regards the buy-in regime, we found reasonable the Proposal to migrate from a mandatory to a conditional application of mandatory buy-in, based on specific conditions and statistics (to be identified, presumably later on in Delegated Acts) monitoring the settlement efficiency (fail rate, etc.) for the Union as a whole. However, as better described in our Response, our analysis of this part of the Proposal raised some concerns, among which in this executive summary we just highlight the fact that it is not clear from the legal text of the Proposal whether the “conditional” buy-in, once activate, would become a permanent requirement. In our view, the buy-in should be activated on a pre-defined time-limited or pre-defined efficiency conditions, so that, once the desired level of settlement efficiency is reached, buy-in is disapplied. Equally important it would be a certain degree of flexibility in disapplying the Buy-in so as to manage any potential shortening of the settlement cycle from T+2 to T+1 (currently under discussion in the US). Further to the above, and prior to the activation of the conditional buy-in regime, in our view, the regulatory framework should envisage and include a Monitoring System on the basis of which the Commission would firstly alert the Union once a given settlement efficiency level is not reached (or alternatively “gone below”), adding the details of the actual aggregated levels of settlement (in)efficiency, and secondly provide for an observation period lasting X months for a closer monitoring. Should the settlement efficiency statistics not turn back and improve during such period, then the Commission would intervene by adopting an Implementing Act providing for the application of the buy-in regime. By this mean, the relevant Stakeholders would be adequately pre-alerted about the presumably forthcoming buy-in application, should the efficiency statistic(s) not improve during the hypothetical Monitoring Period. A market participant should be given the opportunity to act as a buy-in agent for itself considering the current scarcity of buy-in agents in the market that, in turn, makes the appointment even more difficult when coupled with the reluctance of most market makers to operate this role (more elaborated in our attachment). In terms of scope of application of the buy-in, we believe it should be refined to exempt any instructions not related to an effective sell/buy transaction (more elaborated in our attachment). The Proposal reasonably introduces a Pass-on mechanism, considered useful in case of settlement chains to avoid triggering a cascade of failed settlements, each requiring a separate buy-in process. Finally, coming to facilitating CSDs’ access to banking-type ancillary services by allowing CSDs with a banking license to offer such services to other CSDs (which are not authorised), as discussed in the attachment our considerations focus on the actual (not just ‘potential’) increase in the risk profile of such market infrastructures and, in extreme cases, in the risks for financial stability.
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

16 May 2022 · Italian political situation

Meeting with Marco Piantini (Cabinet of Commissioner Paolo Gentiloni)

15 May 2022 · Italian political situation

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

5 Apr 2022 · Banking Union and Capital Markets Union: next steps.

Meeting with Mairead McGuinness (Commissioner) and

31 Mar 2022 · Ukraine sanctions, Banking Union, Basel III

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

30 Mar 2022 · Basel III, CMU

Response to Review of the regulatory framework for investment firms and market operators (MiFIR 2.1)

22 Mar 2022

We support the wide scope of financial instruments subject to consolidation but we do not favour the multiple-CTPs model (a CTP per Asset Class). In our view a single, public and institutional CTP would be more efficient for the final users in terms of number of data sources and overall cost for accessing consolidated data. As for the governance of CTPs, the Proposal foresees competitive privately-owned operators. Such operators will undergo a competitive procedure organised by ESMA. We would have preferred public, institutional CTPs that would be called to recover only operating costs and would not have to respond to for-profit logics. As for the participation scheme to the revenues generated by the CTP in shares, we welcome the introduction of a remuneration scheme for smaller regulated markets supplying data on less liquid shares but we believe the scheme should involve other data contributors, specifically systematic internalisers (SI). This would recognise the efforts SIs did and will continue to do to accomplish their function of liquidity providers whilst the relevant regulatory framework is moving SI requirements closer to those applying to trading venues, apparently not considering i)the very different organizational structure and resources characterizing Sis vs trading venues, ii)the contribution SIs continue to give to the variety of the execution venues and iii)the inherent greater risk the SI business bears to provide liquidity. We find it out of proportionality the increase in par.2 of Art.14 in the pre-trade size quoting obligation for SIs as the new framework would make mandatory to move from the current min. 10% of the SMS, to a new regime increasing by 10-times the same obligation. In our opinion this part of the Proposal shall be reverted to the current regime. Also, we highlight that the proposed amendments to par.3 seem to contradict the MQS requirement set equal to twice the SMS, as the combination of the new par. 2 and 3 will have the effect that SIs’ quotes would be made public only when the sizes are exactly equal to twice the SMS. Further to the proposal above, we suggest amending this part by setting the “obligation to make public firm quotes” for sizes between 10% and twice the SMS (which enhances transparency). Eventually, as for other amendments, • we support the deletion of the NCAs’ discretionary powers on the deferrals for non-equity instruments; • As for PFOF, we acknowledge they raise two sources of concern: competition-related and investor-protection related issues, as also described by ESMA in a Public Statement (July 2021) and understand the basis which the Commission moved from to suggest a tightened regulatory framework for PFOF. The existing MiFID II provisions on conflicts of interest, including those related to inducements and on best execution, have ensured so far adequate protection to clients. We believe that any intervention on this practice should be done in a manner which does not unduly impact the carefully calibrated rules covering investor protection. Hence, the Commission should ensure a firmer enforcement of existing rules and a greater supervisory convergence among EU Member States on this scope. • We do not support the deletion of the exemption – provided for by the Share Trading Obligation current regime – for trades in shares which are non-systematic, ad-hoc or irregular and infrequent, as it demonstrated to offer an appropriate buffer for ad-hoc trades with no undue effects.
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Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur) and Mediobanca - Banca di Credito Finanziario

17 Mar 2022 · EU Banking Package 2021

Meeting with Irene Tinagli (Member of the European Parliament, Committee chair)

15 Mar 2022 · Meeting on Banking Issues

Response to Instrument to deter and counteract coercive actions by third countries

1 Mar 2022

Contenuto della Proposta di Regolamento. Il contenuto della Proposta di Regolamento: i) appare di difficile interpretazione; ii) si focalizza principalmente sul ruolo e sulle attività della Commissione europea; iii) prevede, per l’applicazione di misure di risposta da parte dell’UE, una procedura che appare, a giudizio di ABI, troppo complessa a causa della sua lunghezza e degli oneri che dispone. Tale assetto non sembra essere coerente con la necessità di poter disporre di contromisure certe, adeguate e rapide. Definizioni. In linea con la struttura generale delle Direttive e dei Regolamenti dell'UE, ABI suggerisce di introdurre, nel corpo della Proposta di Regolamento provvedimento, un articolo relativo alle "Definizioni". In tale articolo, ad esempio, si suggerisce l’inserimento della definizione di “coercizione economica” ("coercizione economica" – come precisato nella Relazione che accompagna la Proposta di Regolamento - "si riferisce a una situazione in cui un paese terzo cerca di esercitare pressioni sull'Unione o su uno Stato membro affinché compia una particolare scelta politica applicando, o minacciando di applicare nei confronti dell'Unione o di uno Stato membro misure che incidono sugli scambi o sugli investimenti ") e di ogni ulteriore “termine” ritenuto rilevante contenuto nel testo della Proposta di Regolamento , ai fini delle corretta comprensione di quest’ultimo e della sua conseguente applicazione. Tempistiche. Le tempistiche non sono sempre definite all'interno della Proposta di Regolamento, generando incertezze sulla durata delle procedure vote a dissuadere il Paese terzo dalla adozione di misure di ingerenza indebita, ovvero ad avviare procedure che ne contrastino l’efficacia a protezione dell’UE o di uno dei suoi Stati membri. Ad esempio, l’articolo 3, paragrafo 1, della Proposta di Regolamento prevede che: "La Commissione agisce rapidamente" (per altri esempi, cfr. articolo 4 della Proposta di Regolamento: "La Commissione agisce rapidamente" e articolo 7, paragrafo 1, lettera a), della Proposta di Regolamento: "entro un periodo di tempo ragionevole"). Al riguardo ABI ritiene utile che nel testo della Proposta di Regolamento vengano inserite norme che prevedano tempistiche precise e definibili, al fine di chiarire la durata della procedura della Commissione europea relativa all'imposizione e all'applicazione di contromisure dell'Unione. Perimetro di riferimento. All’articolo 3, paragrafo 3, della Proposta di Regolamento, è riportato quanto segue: “La Commissione può pubblicare un avviso nella Gazzetta ufficiale dell'Unione europea o mediante altri mezzi adeguati di comunicazione pubblica, con un invito a presentare informazioni entro un termine prestabilito”. Il testo della Proposta di Regolamento all’articolo 3, paragrafo 3, non specifica il perimetro di riferimento a cui è rivolta la richiesta di informazioni. ABI evidenzia la rilevanza della definizione di questo perimetro. A tale riguardo, ad esempio, nell'articolo 11 della Proposta di Regolamento, si dispone che la Commissione europea –nell’effettuare la raccolta di informazioni – informa e consulta i portatori di interessi, in particolare le associazioni settoriali, interessati da eventuali misure di risposta dell'Unione e gli Stati membri coinvolti nella preparazione o nell'attuazione della legislazione che disciplina i settori in questione (cfr. paragrafo 3 dell'articolo citato).Impegno con il paese terzo interessato. La Proposta di Regolamento (cfr. articolo 5) stabilisce che la Commissione europea è disposta ad avviare, a nome dell'Unione, un dialogo con il paese terzo interessato al fine di valutare le opzioni per ottenere la cessazione della coercizione economica. Tali opzioni possono comprendere: i) negoziati diretti; ii) la mediazione, la conciliazione o i buoni uffici per assistere l'Unione e il paese terzo interessato in tali sforzi; iii) – l'assoggettamento della questione a un procedimento aggiudicativo internazionale. A giudizio di ABI
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Response to Alternative Investment Fund Managers – review of EU rules

15 Feb 2022

The proposal regarding paragraph 5 of Article 61 of the Directive 2011/61/EU contains an explicit derogation from the obligation in this regard provided for by Article 21 of the same Directive, but it has a generic wording and, as such, it allows for a broad application. This approach is in contrast with the content of the Explanatory Memorandum of the proposal, where: • it is recognized that it is not currently feasible to proceed with the introduction of the depositary's European passport due to the divergences between national securities and insolvency laws and supervisory approaches and the risk of a concentration of the depositary market and lower investor protection; • it is explained that the proposal aims to overcome the difficulties to appoint a depositary in smaller, more concentrated markets, where there are fewer service providers. In its current wording, the proposal risks creating significant problems instead of solving a specific problem. Indeed: • the lack of a provision at the legislative level of the objective conditions under which it is possible to derogate from the general rule, potentially raises the number of cases in which the national competent authorities of each country may use it; • the concept of non-regulated AIF is not defined under AIMD. Therefore, the reference to this case is unclear; • this, in turn, entails the risk of regulatory arbitrage between the various national legal systems. The European alternative fund industry may find it more convenient to set up funds in the countries that have used this derogation in order to be free in appointing the depositary also taking into account their fees which may be proportionate to the level of severity of the different supervisory approaches. Therefore, there is a risk of relocation of the industry in such countries; • the lack of a provision regarding the duties and responsibilities of depositaries operating on a cross-border basis generates in turn legal and application problems. The same can be said for the lack of rules on the coordination of the supervisory powers of the authorities of the different countries involved: the supervisory powers framework set by the AIFMD is currently focused on the nationality of the fund. Prospectively, in the absence of a European passport, the depositary operating cross-border would in any case also remain subject to the supervision and the rules provided by its own national authority. Hence in view of this, it is of the outmost importance that the legislative proposal is integrated with the following provisions: • consistently with the Explanatory Memorandum, paragraph 5 of Article 61 of the AIFMD should expressly indicate that national competent authorities may derogate to the general rule under the conditions that their Member States: ii) have smaller, more concentrated markets, where there are fewer depositaries; ii) provide the European Commission with evidences of the shortage of depositaries; • a clear definition of the types of AIFs which are currently defined as “not regulated AIFs” or alternatively the deletion of such reference; • consistently with the proposed changes to art. 21 (16), it should be clarified that: i) the competent authorities of the Member State where the AIF is established are responsible for ensuring that the depositary complies with the national rules applicable to the AIF; ii) supervisory checks are carried out by the competent authorities of the Member State where the depositary is established on instruction received from the competent authorities of the Member State where the AIF is established; • applicable and updated rules shall be made available by the competent authorities of the home Member State of the AIF in written form and in a language customary in the sphere of international finance. The depositary oversight duties could only ensure the compliance with the written rules made available by the competent authorities of the home Member State of the AIF.
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

15 Feb 2022

ABI supports the establishment of a European Single Access Point as we believe that the proposals for a voluntary contribution scheme open to all companies, the public management of the initiative, entrusted to ESMA, and the free and widespread access to the information will contribute to proceed in the right direction. However, we would like to highlight some issues and open points of the proposal that should be addressed in the coming legislative process. The proposal Regulation provides a very broad scope for the mandatory information to be reported in ESAP, which includes information made public in accordance with almost the European legislations related to the financial markets, the regulation of banks and insurance companies and the rules on sustainability. The proposal to include, at a very first stage in the mandatory regime, almost the regulated information required by the regulations on financial markets, prudential requirements of banks, accounting and financial information and sustainability, makes it difficult for those who are subject to such legislations to be ready within the timeframe indicated by the Commission (31 December 2024). This is also more difficult in consideration of the fact that regulated information is now available in different formats and not necessarily machine-readable. This will also require a time- and resources-consuming process for the authorities and the industry to develop new standards and implement them. Thus, it is suggested to rethink the all-in approach, by proceeding gradually, giving priority to accounting, financial and sustainability related information and those contained in the financial instruments offering documentation. That information is immediately relevant to investors, in line with the main objective of ESAP which is to increase cross-border visibility of enterprises (especially SMEs) for the benefit of potential investors. We support the proposal that access to the information will take place via the web or API and will be in most cases free of charge. As regards the collection of the information, we also support the proposal that such role is taken by public authorities, that will act as “collecting bodies”. However, the duty of submitting the information to the ESAP through the “collecting bodies” by regulated institutions should not turn into a burden for regulated entities that are already required to publish or transmit information to reporting mechanisms, national or European authorities, markets infrastructures or any other existing information storage bodies, system or mechanisms already delegated to receive such information and according to the different legislations in scope. In other words, in order not to create a duplication of reporting activities and to avoid an increase in reporting costs, ESAP should, when possible, collect information directly through existing reporting entities or mechanism. We support the voluntary information regime as drafted in the legislative proposal. However, it is worth underlying that the definition of formats and technical requirements, delegated to ESMA, will be crucial for the setting up of such regime. A balance between the standardization of the information and the reduction of burdens for companies who submit themselves to the voluntary regime, should be found. This would be an important incentive, especially for smaller companies. We also support the introduction in the ESAP voluntary regime of sustainability information as defined in the upcoming Corporate Sustainability Reporting Directive (CSRD) for listed SMEs (which is a simplified version of the EU Sustainability Reporting Standard). This will facilitate investors that might comply to sustainable related legislative obligations, such as the ones defined by the EU Taxonomy Regulation (Delegated Act to Art. 8).
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Response to Alignment of EU rules on capital requirements to international standards (review processes)

8 Feb 2022

The Italian Banking Association (ABI) welcomes the opportunity to comment on the legislative proposal COM(2021) 663, intended to amend Directive 2013/36 (Capital Requirements Directive, CRD), as part of the proposal known as “banking package”. The proposed amendments to the fit-and-proper framework seem to go beyond the objective to ensure a “more consistent, efficient and effective supervision of members of the management body and of key function holders”. In particular, ABI considers critical the envisaged timing of such assessment, which unjustifiably compresses the national framework for the election of the board (slate voting system mechanism - voto di lista) also aimed to protect minorities. At this regard, ABI asks for the possibility of maintaining and recognizing national flexibility. In respect to the ESG risk drivers and sustainability matters, banks’ shifting of resources towards a low-carbon economy and engagement with customers is key in financing the transition. While banks are fully aware of their responsibilities and are committed to play their role, it is not realistic to expect finance to make this shift in the absence of a major change in the incentives of the underlying economy. The Union policy objectives must be transposed in the industrial policies and relevant national legal frameworks. Banks should not be put in the position of being the primary enforcers of climate policy, neither should prudential framework be used as a substitute of direct mechanisms such as taxes or industrial measures. The last paragraph of the attached document is devoted to a proposal aiming at better implement the proportionality criteria in the SREP process. In the attached document, only the key issues are treated, illustrating ABI reasoning. This should be intended as initial feedback, while ABI remains fully committed to provide further advice in the course of the legislative process, with more detailed proposals for amendments on the identified topics (and possible additional points). ABI would be keen to discuss at any time its recommendations with the EU Co-legislators, the European Commission, banking and supervisory Authorities and all relevant stakeholders.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Nicolo Brignoli (Cabinet of Commissioner Mairead Mcguinness) and

12 Jan 2022 · Retail Investments Strategy

Meeting with Agnieszka Skonieczna (Cabinet of Commissioner Thierry Breton)

28 Oct 2021 · SME financing; role of the IT financial sector

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

27 Oct 2021 · Discuss aspects of Basel, in particular minority interests treatment and output floor

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

5 Oct 2021 · Upcoming Basel III package: the position of ABI on the main elements.

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

30 Sept 2021 · Basel III

Response to EU Standard for Green Bond

27 Sept 2021

ABI provides hereinafter first comments on the EU Green Bond Standard Proposal Regulation (EUGBS), adopted by the European Commission in July 2021, which introduces a common framework of rules governing green bond issuances in accordance with the provisions of Regulation (EU) 2019/2088 on Taxonomy. We consider that the alignment with the Taxonomy can increase transparency in the eligibility of the ESG activities, encouraging issuers to tap the market, especially in such economic sectors where the identification of the green assets is not straightforward, and can also increase investors’ confidence in green bonds. We also highlight that the EUGBS has the potential to boost green bond markets widening the range of market standards to be used. However, the proposal introduces an accreditation and supervision regime for verifiers in addition to a new standard report of external verification. While we understand that such regime is needed to reduce the risk of greenwashing, it should be avoided that an increasing of controls on external verifiers leads to a sensible increase of the costs for green bond issuers. We deem it important to support the adoption of the EU green bond standards with some incentives. The use of public guarantee schemes for SMEs (e.g. through the InvestEU program) would improve the credit risk profile for the investors. While prudential incentives for the banks (e.g. sustainable supporting factor) would extend financing or refinancing green eligible activities (those aligned with the Taxonomy and with a perspective financial risk), also through EUGB issuance. The proposed Regulation (art. 6) limits the use of proceeds to only those economic activities that meet the taxonomy requirements, or that will meet the taxonomy in a defined period of time (5 or 10 years). It means focusing green bond only on those activities contributing significantly to the EU environmental objectives. However, there are many activities whose contribution is not considered significant but which, nevertheless, cannot be neglected in a broader effort to guide the transition of the European economy towards a more sustainable model. In addition, nowadays the Taxonomy does not yet cover all relevant activities. In order to tackle such two limitations, it’s important to introduce an appropriate flexibility allowing the proceeds of a green bonds be used also to finance or refinance assets not meeting the Taxonomy requirements (now or in 5-10 years’ time) but nevertheless contributing to a certain degree to the EU objectives or to fix their breaches in term of DNSH. Thus, we propose to introduce for such “transitional” activities a dedicated threshold (e.g. 30%) of the bond’s proceeds. The periodic review of the Taxonomy criteria (art. 7) is seen as a positive feature. However, the potential risk of a bond no longer being considered “green” in the future or the risk to re-allocate bonds proceed to new activities might refrain many issuers from tapping this market. Given that, we believe that the introduction of a 5-year grandfathering (the so-called grace period) for the use of proceeds in case of amendments of the Taxonomy technical screening criteria is not in line with Recital 11 of the proposal, which clarifies that grandfathering is necessary to provide legal certainty to issuers and investors. The consequent reallocation of bond’s proceeds to new activities during the grace period may have an impact on the price and the liquidity of the green bond on the secondary market. Furthermore, unplanned costs might be to incurred by the issuer to reallocate/adapt the bond’s proceeds and by investors to monitor any change in the EUGB. To ensure that the EUGB Standards are aligned with the above needs, we propose to provide that technical screening criteria applicable at the time the green bond was issued are valid until the maturity of the bond. The wording of Article 7(1) 2nd subparagraph and 7(2) 3rd subparagraph should be modified accordingly.
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Response to European Digital Identity (EUid)

1 Sept 2021

The Italian Banking Association (ABI) appreciates the opportunity to provide its feedback through the "Have your say" procedure, given the importance of the topic. We welcome the concept outlined in the proposal, where each Member State shall issue a European Digital Identity Wallet (EDIW) after the entry into force of this Regulation: Identity issuance will remain a Member State responsibility, as it is currently the case for the analogical identity document. States will be able to draw on the support of private players for identity wallets management. In this document ABI submits to your attention its position, which considers as ultimate goal the maximum integration of the various national solutions based on eIDAS through their standardization. In summary, the key elements ABI wishes to highlight are the following: • There is a need for cooperation between European institutions, Member States, and the financial sector by collaborating within the Toolbox, as outlined in the Commission's Recommendation. Furthermore, EDIW should build on existing eIDAS-compliant national digital identity systems, thereby preserving investments already made and ensuring a level playing field. • The high ambitions presented in the initiative are considered a positive development. A new wallet architecture will further stimulate innovation within the financial sector. The founding pillars of this architecture will foster the creation of a digital ecosystem aimed at strengthening the link between physical and digital identities. This will primarily benefit all European businesses and citizens. • European interoperability for the EDIW has to be pursued, otherwise the consequent developments could lead to 27 separate national Digital Identity Wallets, which will inevitably multiply operational costs, inefficiency (e.g., multiple sets of national rules to comply with) and investments needed from the private sector (e.g., European players will have to tune with all the 27 national solutions). • It is necessary to ensure a strong coordination with other existing European rules, like the ones set by AML, GDPR and PSD2. • The significant investments that the banking industry has made in recent years to secure processes should not be compromised by the introduction of new rules. • When the Strong Customer Authentication (SCA) will be done by the EDIW also for payment transactions, the PSPs will lose the control over the customer activity and its ability in preventing fraud will be limited. The concept that the EDIW issuer will become fully responsible for the potential frauds based on customer Identity theft has to be clearly stated in the EDIW regulation.
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Response to Amendment of the Blocking Statute

30 Aug 2021

L’Associazione Bancaria Italiana accoglie con favore la possibilità di commentare la proposta della Commissione relativa alle modifiche del c.d. “Regolamento di blocco”, avanzate al fine di arginare il fenomeno relativo alle conseguenze, per i Paesi dell’UE, di misure sanzionatorie finanziarie adottate da Paesi Terzi. ABI concorda con la volontà della Commissione di creare un contesto normativo moderno e adeguato alla velocità degli scambi finanziari che il mercato richiede in epoca di digitalizzazione di gran parte delle operazioni, come già evidenziato in risposta al questionario inerente la Consultazione relativa alla creazione di uno strumento anticoercitivo. ABI appoggia la proposta della Commissione di realizzare un processo di armonizzazione normativa presso tutti i Paesi dell’UE, in quanto favorirebbe la certezza giuridica nonché la collaborazione fra autorità nazionali, in favore di un più agevole e sicuro svolgimento delle operazioni finanziarie, nel rispetto della disciplina domestica e comunitaria. Tuttavia le emanande modifiche al regolamento dovrebbero portare al superamento del seguente problema, già evidenziato da ABI in occasione della risposta al questionario sul richiamato strumento anticoercitivo. Ai sensi dell’art. 5 del Regolamento di blocco, le banche che venissero obbligate ad effettuare il regolamento, anche in Euro, di transazioni commerciali poste in essere da imprese proprie clienti si troverebbero a subire, da parte dello Stato ingerente, sanzioni che potrebbero causare pesanti ricadute sull'operatività della banca in tutta la sua sfera commerciale. Si pensi alle ricadute operative derivanti ad una banca che, rispettando il citato art. 5, regolasse una transazione, anche in EURO, effettuata da un'impresa UE con controparti non gradite allo Stato Terzo: detto Stato potrebbe, con normativa nazionale, obbligare le proprie banche a non intrattenere attività con la banca UE con l'effetto di determinare la chiusura dei conti di corrispondenza che la stessa banca UE detiene con le banche del Paese Terzo. E' pertanto necessario che ogni iniziativa di revisione del Regolamento di blocco escluda rischi, come quelli sopra evidenziati, prevedendo semmai il ricorso ad un sistema di regolamento delle transazioni indipendente dalle banche commerciali e operato direttamente da soggetti di natura statale riconducibili all'UE (BCE-SEBC-Singole banche centrali dell'UE), limitatamente a tale tipologia di transazioni e senza estendere la portata dell'intervento ad altre attività di regolamento di transazioni commerciali.
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Response to Requirements for Artificial Intelligence

2 Aug 2021

Il documento rappresenta il contributo dell'Associazione Bancaria Italiana (ABI) al dibattito in tema di Intelligenza Artificiale ed è stato redatto con l'attivo contributo dei gruppi di lavoro composti dalle banche associate e da esperti in materia. Nel ringraziare per l'opportunità, rimaniamo a disposizione per ogni approfondimento. Con i migliori saluti, Silvia Attanasio
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius), Sarah Ziane (Cabinet of Commissioner Virginijus Sinkevičius)

14 Jul 2021 · Sustainable Finance

Response to Revision of Non-Financial Reporting Directive

21 Jun 2021

General comments The proposed Corporate Sustainability Reporting Directive (CSRD) is a central component of the sustainability reporting requirements underpinning the EU’s sustainable finance strategy, together with the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation. Ensuring consistent, standardised disclosures from non-financial corporates will be a key factor in enabling banks and other financial market participants to assess the sustainability of their portfolios, and allocate capital effectively in pursuit of the goals of the European Green Deal. Specific remarks The objective of the proposed legal framework is to create a consistent and coherent flow of sustainability information throughout the financial value chain. In order to achieve this, ABI strongly asks the European Commission to consider the following requests: • Expansion of the perimeter to include large non-financial companies is a precondition for enabling financial institutions to comply with the disclosure requirements based on the available information published by those companies. Nevertheless, it must be considered that, due to the nature of their businesses, credit institutions have larger balance sheets than non-financial corporations. As a result, the vast majority of them will exceed the balance sheet threshold specified in the definition of large enterprises set out in the Accounting Directive. In addition, certain disclosures required by the EU prudential regulation for credit institutions apply depending on different size thresholds. We therefore ask, in the case of banks, for partial adaptation of the criteria for identifying large companies. The following two conditions for banks should both be satisfied: - more than 250 employees; and - more than EUR 5 billion in total assets (this latter threshold is also applied in the prudential regulation of identified small and non-complex institutions). These two thresholds should not be modifiable on transposition of the proposed Directive at individual Member State level and should not affect the thresholds specified in other Directives. • Current practice in some countries is to publish a Non-Financial Statement separately from the management report. We ask that this possibility would be maintained in the CSRD as well. We acknowledge the importance of ESG disclosures for investors, but other stakeholders would also be interested in this information and not many of them can easily read a management report. • It is fundamental for ESG disclosures to be made by economic activity, rather than just by legal entity, for consistency with other EU Regulations. • The disclosures of financial institutions depend on the availability of data published by their counterparties; accordingly, banks should only start reporting in accordance with this Directive after at least one year has elapsed from the first disclosures made by non-financial companies. Banks should also be allowed to base their disclosures solely on the public data made available by their counterparties. This aspect should be reflected and harmonised in all the relevant sustainability reporting requirements that underpin the EU’s sustainable finance strategy.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

15 Jun 2021 · Basel III

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

1 Jun 2021 · Basel 3+

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

18 May 2021 · Banking Crisis Management

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

24 Feb 2021 · Basel III, (NPL's) - Non performing Loans

Response to Directive/regulation establishing a European framework for markets in crypto assets

11 Jan 2021

The Italian Banking Association would like to thank the European Commission for the opportunity to provide feedback on the proposed Regulation on a pilot regime for market infrastructures based on distributed ledger technology. Please see document attached.
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Response to Directive/regulation establishing a European framework for markets in crypto assets

11 Jan 2021

The Italian Banking Association would like to thank the European Commission for the opportunity to provide feedback on the proposed Regulation on Markets in crypto-assets (MiCA). Please see document attached.
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Response to COM Delegated Regulation specifying the information referred to in art. 65.9 of the PEPP Regulation

17 Dec 2020

ABI appreciates the EU Commission proposal regarding the Delegated Regulation supplementing the PEPP Regulation with criteria and factors to be applied by EIOPA in determining when there is a significant PEPP saver protection concern which justifies an intervention with regard a particular PEPP product. We agree with the general approach adopted by the Commission in defining these criteria and factors, taking into account the long-term retirement nature of the PEPP, and in providing further detail on what constitutes a threat to the orderly functioning and integrity of financial markets or to the stability of the whole or part of the financial system of the Union, referred to in Article 65. Among the criteria and factors to be applied in these cases, the possibility of an horizontal assessment on the evidence provided by PEPP providers is of utmost relevance. To this end, we believe that a common framework for the evaluation of risk-mitigation techniques, the cost of guarantee and the risk-performance relationship is crucial to avoid different standards at national level that would create room for artificial barriers to the single market for the PEPP. In our view the exclusion of the cost of guarantees from the cost cap for Basic PEPP, without fostering supervisory convergence on how to define the price of long-term guarantees to ensure the fair access of providers to the European market of the Basic PEPP, may create issues with respect to the protection of PEPP savers. PEPP providers may, for example, be incentivized to shift a portion of the other costs to the cost of the guarantee (which is excluded from the cost cap). We acknowledge that in the text of the delegated act the following factor is correctly foreseen among those to be considered for a possible product intervention by EIOPA: “Art 1, letter m) the pricing and associated costs of PEPP, taking into account the following: (i) the use of hidden or secondary charges; (ii) charges that do not reflect the level of service provided; (iii) the costs of guarantees or costs that do not reflect the actual cost or the fair value of the capital guarantee in the case of a Basic PEPP” However, in order to enhance transparency on the price elements by the PEPP providers and distributors, we see an urgent need of developing a common methodology that would enable EIOPA and NCAs to check the fairness of the pricing of the capital guarantee provided. This would ensure the above mentioned supervisory convergence and fair access of providers to the European market of the Basic PEPP. Finally, to ensure a consistent application of the product intervention powers across by Member States we consider fundamental that the same factors and criteria are used by NCAs in the PEPP product intervention assessment.
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Meeting with Peter Power (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

11 Nov 2020 · Discussion on measures to address non performing loans

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Paolo Gentiloni)

2 Oct 2020 · Digital Taxation

Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

This document constitutes ABI's contribution to the consultation launched by the European Commission on the amendments to the MiFID II Delegated Regulation (EU) 2017/565 and the Delegated Directive (EU) 2017/593 regarding the integration of sustainability factors, risks and preferences into certain organisational requirements and operating conditions for investment firms and into the product governance obligations. We have deeply analyzed the content of the current legislative proposals, also in comparison with the previous texts published in May 2018 with the previous consultation, the following ESMA consultation and the relevant ESMA Final Report. At this stage, our main concern is that clarity and coordination between MiFID II and the overall regulatory European framework on sustainability finance will be provided. We therefore highlight in the following paragraphs the main comments and the relevant changes deemed necessary to achieve this aim.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

This document constitutes ABI's contribution to the consultation launched by the European Commission on the amendments to the MiFID II Delegated Regulation (EU) 2017/565 and the Delegated Directive (EU) 2017/593 regarding the integration of sustainability factors, risks and preferences into certain organisational requirements and operating conditions for investment firms and into the product governance obligations. We have deeply analyzed the content of the current legislative proposals, also in comparison with the previous texts published in May 2018 with the previous consultation, the following ESMA consultation and the relevant ESMA Final Report. At this stage, our main concern is that clarity and coordination between MiFID II and the overall regulatory European framework on sustainability finance will be provided. We therefore highlight in the following paragraphs the main comments and the relevant changes deemed necessary to achieve this aim.
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Meeting with Paolo Gentiloni (Commissioner)

28 May 2020 · Covid-19 impact in Euro and Italian area

Meeting with Marco Piantini (Cabinet of Commissioner Paolo Gentiloni)

5 Mar 2020 · COVID-19

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

4 Feb 2020 · Basel 3, CMU and Sustainable finance

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

23 Jan 2020 · Economic situation in Italy; Discussion on Basel III with a particular focus on SMEs and green investment

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

21 Jan 2020 · ABI reflections on Banking Union and Capital Market Union

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

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

5 Sept 2019 · Banking regulation

Meeting with Stefano Manservisi (Director-General Directorate-General for International Partnerships)

27 Mar 2019 · Meeting with Mr Cornelli - Exchange about new sustainable finance instruments

Response to Amendments to the implementing rules on solvency applicable to insurers

7 Dec 2018

ABI welcomes the changes outlined in paragraph 38 of the draft, describing an assessment of credit quality steps (CQS) for unrated (by ECAIs) bonds and loans based on an approved internal model (Art. 176 C) which allows to lower the capital charges for these assets, introducing an assessment not overly complex and to remove unjustified constraints to the financing of the economy. Indeed, unrated debt represents not only an important investment asset for the industry, but also a key source of funding for SMEs in Europe, as highlighted in the CMU objectives. As a more general comment, ABI highlights that the treatment of unrated debt should be reviewed to better reflect: - the actual risk that insurers are exposed to when investing in these assets, which is credit risk and not market spread risk, as insurers are not exposed to forced sales of these assets that are illiquid; - the need for an extension of the scope to CQS 4, to allow for a wider coverage across member states. Please find in the attached document more specific comments on the assessment of credit quality steps of bonds and loans on an approved internal approach.
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Response to EU small listed companies Act

25 Jul 2018

Please find enclosed ABI's remarks to the EU Commission proposal for a Regulation of the European Parliament and of the Council amending Regulations (EU) No 596/2014 and (EU) 2017/1129 as regards the promotion of the use of SME growth markets.
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Meeting with Arianna Vannini (Cabinet of High Representative / Vice-President Federica Mogherini)

27 Jun 2018 · Banking Union

Response to EU small listed companies Act

21 Jun 2018

Please find enclosed ABI's remarks to the EU Commission delegated regulation proposal amending Commission Delegated Regulation 2017/565 as regards certain registration conditions to promote the use of SME growth markets for the purposes of Directive 2014/65/EU of the European Parliament and of the Council.
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Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

Please find enclosed ABI’s remarks on the EUROPEAN COMMISSION on the Draft Delegated Regulation amending Regulation (EU) 2017/565 supplementing Directive 2014/65/EU as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive.
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Response to Statutory prudential backstops addressing insufficient provisioning for newly originated loans that turn non-performing

25 May 2018

Please find here enclosed the comments of the Italian Banking Association. Best regards
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

11 Apr 2018 · Banking Union Package

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

21 Nov 2017 · Financial services agenda

Meeting with Federica Mogherini (High Representative / Vice-President)

11 Oct 2017 · Banking Union

Meeting with Arianna Vannini (Cabinet of High Representative / Vice-President Federica Mogherini)

28 Sept 2017 · Financial services

Meeting with Massimo Suardi (Cabinet of Vice-President Valdis Dombrovskis)

30 Mar 2017 · update on banking regulation and review of BRRD and SRMR

Meeting with Massimo Suardi (Cabinet of Vice-President Valdis Dombrovskis)

28 Sept 2016 · Basel, BSR

Meeting with Marco Buti (Director-General Economic and Financial Affairs)

24 May 2016 · Non-performing loans and "Atlante" fund

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

14 Apr 2016 · Italian economy and banking sector

Meeting with Arianna Vannini (Cabinet of High Representative / Vice-President Federica Mogherini)

1 Dec 2015 · Banquing Union

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

23 Jul 2015 · Situation of the banking sector and the economy in Italy in general

Meeting with Matthew Baldwin (Cabinet of Commissioner Jonathan Hill)

12 May 2015 · Financial Policy

Meeting with Valdis Dombrovskis (Vice-President) and

13 Apr 2015 · Meeting with social partners