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Associazione Italiana Private Banking

AIPB

AIPB is a non-profit organization founded in 2004 to promote and sustain Private Banking as a distinct part of the Italian financial industry.

Lobbying Activity

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque)

17 Sept 2025 · Courtesy Meeting

Response to Recommendation on savings and investment accounts

7 Jul 2025

Dear Sir or Madam, Please find attached the AIPB feedback to the Call for Evidence on the Savings and Investment Account Initiative. Best regards, AIPB Associazione Italiana Private Banking
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Response to Revision of EU rules on sustainable finance disclosure

30 May 2025

Dear Sirs, please find attached the feedback provided by the Italian Private Banking Association.
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Meeting with Pasquale Tridico (Member of the European Parliament)

20 Mar 2025 · meeting with ’Associazione Italiana Private Banking (AIPB)

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque)

19 Mar 2025 · AIPB presented their company and activities

Response to Savings and Investments Union

7 Mar 2025

Dear Sirs, AIPB key proposal are the following: (a) Acknowledging the Role of Private Banking one of the key goals of the SIU should be channeling savings held by private banking institutions into SMEs and fostering economic growth through tailored advisory services and specialized financial products. The existing regulatory framework does not take into account the specific features of private banking business; (b) Introducing special rules on semi-professional Investors: the introduction of semi-professional investors could enhance capital allocation within the EU market. The MiFID2 regime for retail clients should focus on general retail investors with limited capacity and savings and be simplified for such investors; (c) MiFID2 Simplification some of the MiFID2 rules resulted in an over-protection and paternalistic approach towards retail investors. EU institutions should consider simplifying the suitability and appropriateness assessment as well as the disclosure requirements to ensure a more effective regulatory framework; (d) Simplified Disclosure Obligations the existing MiFID2 regime often leads to information overload and excessive reliance on compliance-based safeguards, which can diminish the quality of investment decisions; (e) EU Rules on Individual Savings Plans some Member States have established national tax regimes to reduce taxation on the returns generated as a result of the investment in individual saving plans. Investment funds, insurance policies and portfolio management services could be eligible to benefit for this specific tax treatment. The EU institutions could establish a common framework for the creation of EU Individual Saving Plans which would serve as a basis for Member States to define specific tax benefits according to national policies; (f) EU Retail AIF ELTIF 2.0 Regulation could constitute the basis to create a harmonized EU AIF product marketed to retail investors with higher flexibility in terms of investment strategies. Additional proposals are: (a) Further Harmonization of Financial Services the EU should establish a passporting regime to harmonize the regulatory framework applicable to fiduciary companies, family offices and non-bank lenders across the EU, as well as to other services that are not currently regulated at EU level. Banks and investment firms should already be allowed to offer these services; (b) Partial opt-out from existing pension regimes EU citizens should be entitled to opt-out on a voluntary basis from existing mandatory pension regimes managed at national level and invest part of their pension savings in harmonized EU pension products; (c) Common EU rules on start-up and SMEs a new EU regulation establishing common rules on the incorporation, management and operations of EU start-ups and SMEs would help startups to scale and access cross-border funding. The regulation could introduce simplified procedures for the issuance of financial instruments by EU start-ups and SMEs, as part of a broader effort to facilitate their access to capital markets; (d) EU Permanent Sandbox the establishment of an institutionalized and permanent EU financial sandbox would foster innovation while ensuring regulatory clarity and investor protection. A consistent and predictable regulatory environment for fintech firms, financial institutions, and emerging financial technologies; (e) Simplifying EU legislation the structure and layers of the EU financial services legislation should be simplified to facilitate the identification of the requirements that apply to the provision of financial services; (f) Reviewing the role of ESAs the role of ESAs should be revised by entrusting them with the power to tackle gold-plating rules and to ask the Commission to refer the matter to the CJEU. At the same time, EU citizens should be allowed to challenge soft-law guidelines or recommendations issued by the ESA in front of EU Courts. Please see the attached document. AIPB
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Response to Open finance framework

1 Nov 2023

Please find enclosed the AIPB (Italian Association of Private Banking) feedback on the European Commissions Proposal on Financial Data Access (FIDA). Best regards, AIPB
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Response to Environmental, social and governance (ESG) ratings and sustainability risks in credit ratings

31 Aug 2023

Please find enclosed the AIPB (Italian Association of Private Banking) feedback on "Sustainable finance environmental, social and governance ratings and sustainability risks in credit ratings". Best regards AIPB
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Response to Retail Investment Package

28 Aug 2023

Please find enclosed the AIPB (Italian Association of Private Banking) feedback on Retail Investment Strategy. Best regards, AIPB
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Response to Long Term Investment Funds – Review of EU rules

24 Mar 2022

The reform of ELTIF Regulation plays an important role, given that ELTIFs didn’t spread as expected. We warmly welcomed the innovations set forth by the remarkable “Proposal for a regulation” and we bring to your attention some additional proposals. The current Regulation provides for a quite lengthy and complex authorisation process (i.e. two months plus suspension periods, if any) and this could to be one of the main reasons that prevent asset managers from establishing ELTIFs, especially when compared to the timing required to establish an AIF. In this respect, the innovation facilitates the authorisation of the ELTIF and streamline the separation between provisions that address the authorisation of the ELTIF and those relating to the authorisation of the AIFM. It would be also worth reducing the timing for the authorisation in order to improve the competitiveness of ELTIFs (e.g. one month instead of two months). The Proposal broadens the scope of eligible investment assets in a manner that is both suitable for the optimal execution of investment strategies by ELTIF managers and consistent with the goal of long-term sustainable growth. In this respect, we would suggest some additional changes aimed at further improve the effectiveness vis-à-vis SMEs. We would suggest including among the eligible investment assets all forms of ‘credit’ (i.e. “loan origination”, “loan participation”, or “loan restructuring”). In addition to loans granted by the ELTIF it would be useful to include existing loans originated by third parties and receivables, as from a pay-off perspective, all these activities are aimed at providing credits to SMEs. For example, please consider that the long-term of the ELTIFs may be used to extend the duration of existing loans moving the relevant underlying towards patient capital. Please also consider that has been noted a significant interest from institutional investors in the market of commercial receivables of SMEs. This mechanism provides liquidity to the undertakings against the sale of the commercial receivables instead of seeking financing. It would be useful to include within the list of eligible investment assets participations, debt instruments in qualifying portfolio undertakings, loans provided to them both in the form of loan participation and loan origination and receivables (of which the qualifying portfolio undertaking is a creditor). It was very much appreciated that the Proposal sets out changes reducing the value of individual real asset from EUR 10.000.000 to EUR 1.000.000. It could be also useful to include within that the capital expenditures in relation to the construction, development, reconversion, restructuration and restoration of the real estate assets. In addition, it would be useful to specify that the above investment limit (EUR 1.000.000) refers to all the properties belonging to the same compendium properties subject to a functional destination of use. We take this opportunity to reiterate – within the Capital Market Union implementation process – that the need to increase the number of clients eligible for illiquid instruments (in particular for AIFs reserved to professional clients which represent a broader category that includes closed-end funds on which the same mechanism of ELTIF does not seem to be replicable through the creation of retail funds) would be facilitated by the recognition of an autonomous positive target market substantially coinciding with private banking clients, allowing the allocation of illiquid products to the new category of semi-professional investors. We hope that the future revision of AIFMD and MIFID 2 frameworks would consider the reform of the client categories, assigning the right value and weight to the target market representing private banking clients (minimum portfolio > 500.000,00 €; provision of advanced advisory or portfolio management services; assistance from adequately trained professional staff).
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Response to Long Term Investment Funds – Review of EU rules

14 Oct 2020

Dear Sirs, please can find enclosed the AIPB (Italian Association of Private Banking) feedback. Best regards, AIPB
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