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BANCO BILBAO VIZCAYA ARGENTARIA

BBVA

BBVA is a global bank founded in 1857 with leading positions in Spain, Mexico, South America and Turkey, focused on customer-centric digital banking.

Lobbying Activity

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

22 Oct 2025 · Omnibus Taxonomy DA

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

22 Oct 2025 · Revised taxonomy delegated act

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

22 Sept 2025 · Financial services policy

Meeting with Jonás Fernández (Member of the European Parliament) and Asociación Española de Banca and Federation of European Securities Exchanges

18 Sept 2025 · Saving and Investment Union and sectorial priorities

Meeting with Alexandra Jour-Schroeder (Deputy Director-General Financial Stability, Financial Services and Capital Markets Union)

17 Sept 2025 · Competitiveness in the banking sector and regulatory simplification

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

1 Jul 2025 · Financial services policies

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Airbus and

12 Jun 2025 · High-level Roundtable on Colombian energy sector with exchange of views between Minister of Mines and Energy, IFIs and EU companies.

Meeting with Maria Luís Albuquerque (Commissioner) and

3 Jun 2025 · Information Exchange

Meeting with Mette Koefoed Quinn (Head of Unit Climate Action)

30 Apr 2025 · Review of the EU Emissions Trading System and of the Market Stability Reserve

Meeting with Borja Giménez Larraz (Member of the European Parliament, Rapporteur) and Banco Santander, S.A. and

8 Apr 2025 · Housing crisis in the European Union

Meeting with Jonás Fernández (Member of the European Parliament)

26 Mar 2025 · Economic priorities

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

25 Mar 2025 · Regulatory Simplification-Omnibus Directive and European Competitiveness.

Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra), Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra) and

19 Mar 2025 · Exchange of views on international tax issues

Meeting with Andrius Kubilius (Commissioner) and

25 Feb 2025 · Financial sector on defence, investment policies, EU regulatory framework

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

21 Jan 2025 · Competitiveness of EU regulatory framework and international regulatory fragmentation, Savings and Investments Union and the Digital Euro

Meeting with Mirzha De Manuel (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

21 Jan 2025 · Exchange of views on the implementation and simplification agenda of the Commission, and potential simplification of sustainability reporting

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

16 Jan 2025 · Commission’s priorities for the upcoming mandate

Meeting with Jennifer Robertson (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Deutsche Bank AG and BNP PARIBAS

10 Jan 2025 · EMIR

Meeting with Axel Voss (Member of the European Parliament) and Better Europe

17 Sept 2024 · Corporate Sustainability Due Diligence

Meeting with Thierry Breton (Commissioner) and

4 Dec 2023 · Telecom policy and investments

Meeting with Othmar Karas (Member of the European Parliament)

30 Nov 2023 · Digitaler Euro

Meeting with Mairead McGuinness (Commissioner) and

14 Sept 2023 · Sustainable Finance and Payments, Digital Euro

Meeting with Jonás Fernández (Member of the European Parliament, Rapporteur) and Banco Santander, S.A. and Asociación Española de Banca

27 Apr 2023 · EU Banking Package 2021

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

27 Apr 2023 · Digital Euro

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Banco Santander, S.A. and Asociación Española de Banca

27 Apr 2023 · digital euro (with Cab Dombrovskis)

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

14 Feb 2023 · Retail investment strategy

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

14 Feb 2023 · Retail investment strategy. ETFs.

Response to Instant Payments

23 Dec 2022

We would like to thank you the European Commission for the opportunity to provide feedback on this proposal for a Regulation. In the attached document you can find our detailed comments on the proposal
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BBVA demands stricter proof for AI liability claims

25 Nov 2022
Topic — New EU rules adapting civil liability to the challenges of AI technology.
Message — BBVA wants claimants to prove specific damages and provide detailed economic calculations. They argue current wording breaks down traditional burden of proof obligations.1
Why — The bank would avoid legal uncertainty and unjustified demands for financial compensation.23
Impact — Victims of AI malfunctions would face significant hurdles to obtain legal redress.4
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and European Banking Federation and Associazione Bancaria Italiana

21 Oct 2022 · Digital Euro

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

21 Oct 2022 · digital euro

Meeting with Pelayo Castro (Cabinet of High Representative Josep Borrell Fontelles) and Banco Santander, S.A. and Asociación Española de Banca

19 Oct 2022 · Latin America, digitalization, artificial intelligence and data protection.

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness), Nicolo Brignoli (Cabinet of Commissioner Mairead Mcguinness)

12 Sept 2022 · Financial literacy

Meeting with Frans Timmermans (Executive Vice-President) and Deutsche Bank AG and

6 Sept 2022 · Energy situation in the EU; financing of the green transition

Response to Review of EU rules on payment services

1 Aug 2022

As already pointed out in our response to the targeted consultation on the PSD2 review as well as in AEB’s and EBF’s ones, we think the Commission should make a distinction between the ‘core provisions’ on payments (transparency and information requirements and users and providers rights and obligations, mainly), the scope of PSD2 and the open banking requirements in PSD2. First, the ‘core provisions’ on payments have worked well and have achieved the intended targets: increased competition, security and customer protection. Consequently, introducing new obligations such as a mandatory validation of the name and the IBAN of the payee or new refund rights for fraudulent transactions would introduce frictions in the processing of payment transactions without bringing additional benefits. Similarly, we think there is no reason to extend SCA requirements to more payments, since users already have extended rights to get a refund of transactions not subject to SCA and friction in some e-commerce transactions would be increased. Furthermore, there is no need for regulation to introduce specific provision on instant and cross-border payment. Instant payments are already compatible with PSD2 and PSD2 provisions are not hindering its offering and adoption. On the other hand, new requirements on non-intra-EU cross-border payments would be very difficult, if not impossible, to meet for European PSPs and could lead to an unlevel playing field, as non-EU providers would not be subject to these obligations. Bearing all the above in mind and the huge investments required for adapting payment services and processes to new requirements, we believe there is not a compelling need to undertake changes. Nevertheless, as the payment market is highly dynamic and in order to ensure PSD2 obligations evolve accordingly, there could be merit for the Commission to consider making PSD2 provisions more principle-based and mandating the EBA to further specify them in close collaboration with all the stakeholders when needed. This would, for instance, allow SCA requirements to be adapted to innovations in authentication methods arising on the market or more easily removing frictions created by the obligation of PSPs to allow TPPs to leverage all authentication mechanisms provided to the user. With reference to the scope of the Directive, we think the Commission should focus on bringing new services and providers in scope in order to remove competitive imbalances that already exist or could arise in the future. In particular, digital wallets and payment aggregation should be identified as payment services to remove the regulatory asymmetry that non-PSP providers of those services are taking advantage of. Also, payments using cryptocurrencies or CBDCs should be subject to the same obligations. Additionally, certain exclusions should be modified to bring into scope payment services provided through a commercial agreement, all ATM services and technical services associated with the provision of payments. The latter should ensure that the providers of technical services or elements used for executing payment transactions cannot deny responsibility when there is a malfunction that affects the payment execution. On the contrary, Buy Now Pay Later is a ‘lending’ functionality, not a payment service, that should be covered by the consumer credit legislation. Finally, we think that the open banking requirements in PSD2 have not worked as expected and believe that before moving forward in open finance, the Commission has to take account of the lessons learned from PSD2 as well as create the right incentives for the successful development by the market of an open finance framework. Both issues are further explained in the AEB and EBF responses to the targeted consultation on open finance.
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Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

27 Jun 2022 · European Digital Identity proposal (eID) and Data Act

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Deutsche Bank AG and

20 Jun 2022 · Implementation of sanctions

BBVA Urges EU to Expand Data Sharing Across All Sectors

10 May 2022
Topic — The European Commission is establishing new rules for fair data sharing and access.
Message — BBVA calls for a broader framework including data from different sectors like telecommunications and utilities. They support mandatory compensation for data holders and clearer cloud switching rules.123
Why — Accessing cross-sectoral data helps the bank improve credit assessments and financial products.4
Impact — Large digital platforms lose the ability to restrict data access for competing services.5
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Deutsche Bank AG and

7 Apr 2022 · open finance

Meeting with Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis)

16 Mar 2022 · Economic Impact of the crisis of Ukraine, delivery of sanctions

Meeting with Margrethe Vestager (Executive Vice-President) and

2 Feb 2022 · Data Act

Meeting with Lucia Bonova (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

13 Dec 2021 · Data Act

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Banco Santander, S.A. and Asociación Española de Banca

20 Oct 2021 · Basel III (The meeting was shared with the Cabinet Dombrovskis)

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

20 Oct 2021 · Basel III

Meeting with Valdis Dombrovskis (Executive Vice-President) and Deutsche Bank AG and

23 Sept 2021 · Economic recovery; Situation of the EU financial sector; sustainable finance

Response to Requirements for Artificial Intelligence

5 Aug 2021

We welcome this opportunity to provide feedback to this important regulatory proposal that will undoubtedly influence the future development of AI in the EU. Although the proposed Regulation is quite balanced, we have identified some areas where there is room for improvement: Legal uncertainty. Some provisions in this draft regulation are not specific enough, which could give rise to different interpretations by authorities and market operators and, therefore, create legal uncertainty and hinder the compliance with this Regulation. Definitions are one of the main sources of uncertainty, either due to their vagueness or their absence. In particular, the definition of AI proposed in Article 3 and the techniques listed in Annex I can bring any automatic system or system automating some basic tasks in scope. Other terms such as ‘natural persons’, ‘output’ or ‘(unfair) bias’ should be defined in order to make clear what is intended to be solved and ensure that the final text applies to any legal or natural person leveraging high-risk AI systems for their business activity. With reference to the scope of the Regulation, the Commission should clarify that use cases such as collections, Anti-Money Laundering controls and biometric identification on device are not considered high-risk. In any case, when some ambiguity remains and interactions with other regulations such as GDPR exist, guidance, recommendations or binding opinions to be developed by the Commission or the European Al Board seem paramount. Supervision and governance. It is highly important to ensure that non-financial firms competing with credit institutions and providing or using the same high-risk AI systems as financial entities are subject to similar regulatory and oversight requirements. Also, in order to ensure a level playing field between companies providing and using AI systems for the same purpose, the opinions and recommendations issued by the European AI Board should be binding for national authorities and be based on the criteria established by the authority(ies) with the highest expertise on each particular activity. Finally, APIs should not be imposed as a mechanism for authorities to exercise their access rights, since this would probably require large investments without bringing significant benefits to market surveillance. Bias and discrimination detection. We would prefer the Regulation referred to ‘unfair bias’, not bias, and a definition of the term were provided. Additionally, requirements on the examination of possible biases and the identification of any possible data gaps or shortcomings should be realistic and take into consideration the current state of the art. Regarding the provision of a legal base for processing special categories of personal data for detecting and correcting biases, we think it is not necessary as this is not the ‘silver bullet’ of bias elimination and could reduce citizens’ trust on AI technology. Requirements on high risk AI systems. Some of the proposed requirements are not sufficiently specific or do not reflect the actual state of the art. For instance, it is not clear if full automation of some processes embedding AI would be possible, and criteria on how to decide the type of human oversight that is needed are not provided. Moreover, further clarity is needed on what is meant by requiring the data has “appropriate statistical properties”, the scope of the technical documentation to be provided or what is understood by a substantial change in a system. On the other hand, record keeping obligations should be more flexible and acknowledge that logging capabilities are not the only option to satisfy them. We attach a document where we explain in more detail the above issues
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Response to Revision of Non-Financial Reporting Directive

13 Jul 2021

Banco Bilbao Vizcaya Argentaria (BBVA) welcomes the proposal adopted by the European Commission on April 21st, for a Corporate Sustainability Reporting Directive (CSRD), which would amend the existing reporting requirements of the NFRD. To date, the information provided under the current framework is scarce, incomplete and hardly comparable. We believe the new proposal is a major step towards the improvement of ESG data availability and comparability for market participants to drive the capital flows that are necessary for the transition to a sustainable economy. The proposal is very much in line with the contribution BBVA shared with the European Commission in June 2020, in response to the public consultation on the revision of the non-financial reporting directive. We particularly welcome the extension of the scope to all large companies and all listed companies, the decision to adopt mandatory sustainability reporting standards, a more detailed reporting requirements and the limited assurance of the information reported, as well as the requirement to digitally ‘tag’ the reported information to ensure it feeds into the European single access point envisaged in the capital markets union action plan. The CSRD proposal therefore brings relevant new elements that will significantly improve the ESG disclosure framework. Nevertheless, we would like to take this opportunity to also raise some concerns or challenges remaining, including: - The need of an even more ambitious scope, eventually by including non-listed SMEs belonging to sectors with higher transition risk. - Further regulatory consistency between the CSRD and other regulatory initiatives requiring sustainability disclosures (such as SFDR, the Taxonomy Regulation, Pillar III disclosures, etc.). - International convergence of reporting standards: coordination at a global level, specifically with the IFRS Foundation, in order to ensure international convergence for reporting standards, is urgently needed. - The appropriateness of limited assurance, at least for the first phase of reporting. These positions are further developed in the attached document. Banco Bilbao Vizcaya Argentaria (BBVA) is a global financial group, founded in 1857, that operates a customer-focused retail business model, offering clients a comprehensive range of financial and non-financial products and services around the world. BBVA has a leading position in the Spanish market and it is the biggest financial institution in Mexico. It has also leading franchises in South America, as well as significant presence in Turkey (through strategic investments in Garanti Bank) and operates an extensive network of branches worldwide.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association for Financial Markets in Europe and

27 Apr 2021 · Sustainable Finance

Response to Digital Operational Resilience of Financial Services (DORFS) Act

15 Feb 2021

Please check the enclosed position note with our feedback.
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Response to Directive/regulation establishing a European framework for markets in crypto assets

11 Jan 2021

BBVA welcomes the EC’s proposal to regulate the issuance of different types of crypto-assets as well as the provision of related services, as it is broadly consistent with the principle of "same activity, same risk, same regulation". However, some specific provisions should be further clarified and some issues related to financial stability require further consideration. Details of BBVA feedback are included in the attachement (pdf).
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

24 Nov 2020 · Digital Markets Act

Meeting with Nathalie De Basaldua (Cabinet of Commissioner Mairead Mcguinness)

29 Oct 2020 · Introductory meeting

Meeting with Margrethe Vestager (Executive Vice-President)

22 Apr 2020 · To discuss data policy; global digital competition

Response to Gender equality in the EU

12 Feb 2020

Banco Bilbao Vizcaya Argentaria (BBVA), a global financial services group with more than 125,000 employees, supports the European Commission’s initiative to work on a new Gender equality strategy 2020-2024 and welcomes the opportunity to provide its feedback on the Roadmap published by the Commission the 16th of January 2020. See document attached. From an employer’s perspective, we are particularly interested in sharing our views and individual initiatives aiming at promoting gender equality, since achieving a diverse and inclusive working environment has been defined as a strategic objective for the bank, aligned with our purpose and values. It is also part of the Group’s efforts to contribute to the achievement of the Sustainable Development Goals (SDG). We put a premium on being diverse and inclusive in our business, not only because we know it’s the right thing to do, but also because it’s smart business. We firmly believe that diverse companies are the best companies, they make better decisions, they are more successful in their markets, and all of this has a positive impact on results. Our comments on the proposed topics to be addressed by the new Gender equality strategy of the European Commission are based on the results of a quantitative and qualitative analysis of gender diversity in BBVA Group. This analysis has helped us identify in which areas of the organization we need to take further action, and we have defined a work plan on that basis. We are happy to share our conclusions in the attached document, that we hope can be inspiring in terms of necessary policy actions. We remain at the disposal of the European Commission to share further details of our experience and best practices in promoting gender balance, as well as explore possible ways of collaboration with the European Institutions and other stakeholders.
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Meeting with Phil Hogan (Commissioner) and

20 Jan 2020 · Trade Issues

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

4 Apr 2019 · Roadmap to completion of banking Union and the future of Euribor.

Meeting with Alvaro De Elera (Cabinet of First Vice-President Frans Timmermans)

7 Feb 2019 · Rule of Law

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

10 Dec 2018 · Sustainable Finance

Meeting with Andrus Ansip (Vice-President) and

18 Oct 2018 · Cybersecurity

Meeting with Valdis Dombrovskis (Vice-President) and

8 Oct 2018 · Digital transformation of the banking industry and FinTech, Banking package, Spanish banking sector

Meeting with Carlos Moedas (Commissioner) and

8 Oct 2018 · Digital transformation in the financial sector

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

8 Oct 2018 · Digital Transformation for the banking sector, Digital skills in EU, perspectivies 2020-2025

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Deutsche Bank AG and

20 Sept 2018 · Cyber Security and FinTech

Response to Sovereign bond-back securities product regulation

27 Jul 2018

We welcome the opportunity to give feedback to the Commission’s recent proposal on Sovereign Bond-Backed Securities (SBBS). The legislative proposal gives light on some issues that were still uncertain after the different academic working papers and the ESRB analysis. We share the Commission’s views on the various and positive effects that SBBS could have for financial stability: On the one hand, SBBS would work as a truly low-risk euro-denominated asset that could address some of the remaining problems of the Eurozone. It would tackle the problem of the lack of a European safe asset, facilitating the implementation of monetary policy and planting the seed for a future fiscal union. SBBS could also help in terms of diversification of sovereign exposures in banks’ balance sheet, given that every SBBS implies an exposure to a part of the sovereign risk of every Eurozone Member State. Moreover, SBBS could reduce financial fragmentation, increasing the investor base of the sovereign exposures of Member States that before could not have access to. It could work as a complement for the Banking Union and the Capital Markets Union, working towards private risk sharing and facilitating cross border investment. Nevertheless, we are concerned that the Commission’s proposal includes several features that could damage the path for the development of SBBS. There is still a certain lack of concretion in the proposal, especially regarding design aspects of the issuance. Using the ECB capital key to purchase the pool of national bonds can be challenging as the SBBS market grows bigger for two reasons: 1) the SPV would absorb a significant portion of the outstanding debt of countries with low debt- to-GDP ratios (those countries which are fiscally sound, including some countries rated AAA); and 2) the normal issue pace of these countries cannot ensure a stable contribution to the pool. The Commission proposal does not define a concrete structure of SBBS tranches. It only states that the 70% of the issuance must be a senior tranche, leaving the composition of the 30% to the discretion of the SPE. With the possibility of several SPV issuing SBBS, we consider that this is goes against achieving a much needed homogeneity in a new product, especially one that is a securitization. Regarding this tranche structure, we consider that the proposal on the ESRB report would work better for SBBS. Dividing the junior tranche into a mezzanine and a truly junior tranche (i.e. “first-loss tranche”) would allow the junior SBBS to act as an extra protection layer for holders of mezzanine and senior SBBS. The proposal also envisages a demand-led process to issue SBBS. This is another obstacle to build a sufficiently big SBBS market as to ensure critical features of these bonds, such as liquidity. Achieving a well-functioning market is essential to guarantee the demand of the new assets. Moreover, the first issues of SBBS might be challenging. It remains unclear whether the market would demand a non-existing asset whose junior tranches remain unspecified. Regarding the issuer, the Commission envisages a private issuer for SBBS. The ESRB report did not show a preference for a private or a public issuer. From our point of view a public issuer would: 1) strengthen market’s confidence in SBBS without including mutualisation; 2) show the market that there is a strong public commitment to create a large, liquid market for SBBS; and 3) guarantee that the structure and characteristics of the subsequent issues of the SPE are identical to the first ones by keeping the size and composition of the junior tranches unchanged, given that the goal is to create a sufficiently large market for SBBS (the senior tranche). The introduction of a specific regulatory framework for SBBS is welcome and positive. It is key that SBBS receive a coherent treatment in respect of the underlying assets.
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Meeting with Vivian Loonela (Cabinet of Vice-President Andrus Ansip) and Airbus and

21 Jun 2018 · Cybersecurity package

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Association for Financial Markets in Europe and

6 Jun 2018 · Cyber security, Fintech

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

23 May 2018 · digital transformation of the Banking sector

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

23 May 2018 · Digital transformation of the banking sector

Meeting with Vivian Loonela (Cabinet of Vice-President Andrus Ansip) and Deutsche Telekom and

5 Mar 2018 · Exchange on the proposed Cyber Security, on the certification framework and the future mandate of the ENISA/European Cyber Security policy

Response to Review of the European Supervisory Authorities

22 Jan 2018

BBVA welcomes the opportunity to comment on the European Commission’s (Commission) published Draft to review of the European System of Financial Supervision. The role of the ESAs has been and will continue to be key, in this sense the current European supervisory set-up has proven to be efficient, maintaining market stability and integrity in times of market stress. Morever, further harmonisation would help to create a CMU, which is of significant importance to foster growth and create a level playing field. It is important to rationalise and centralise supervision in certain areas of the financial industry. However, supervisory structures should be re-calibrated carefully, to ensure structural stability, given that relevant EU legislation is still in the process of implementation. In order to provide a positive environment to develop business, and create jobs and growth. BBVA fully supports the overall goal of the ESAs review package aimed at (i) reinforcing coordination of supervision across the EU, (ii) extending direct capital markets supervision by ESMA, (iii) improving governance and funding of the ESAs and (iv) promoting sustainable finance and FinTech. Nevertheless, some of the Commision proposals should be reconsidered (such as ESMA direct supervision of certain types of prospectuses). In this sense BBVA would like to highlight its concerns and priorities. BBVA’s main suggestions are as follows (Please see attached feedback document): - EU Rulemaking processes and ESAs involvement. The ESAs should have: i. A more prominent role in the development of level 1 legislations by, for example, giving them an observer status in the negotiations with the co-legislators. ii. More independence when drafting level 2 legislation. In order to enhance their quality, ESAs should have a reasonable amount of time to draft level 2 legislations. iii. A more transparent process when drafting level 3 texts such as Q&As, guidelines and recommendations. These should always be developed once the corresponding level 2 documents are adopted and should be fully aligned. Importantly, the ESAs should not deviate from their mandate when preparing level 3 texts (i.e., guidelines should focus on ensuring the common, uniform and consistent application of Union Law, and not emulate level 1 primary legislation). The industry and the stakeholder groups should be consulted prior to the enactment of level 3 legislations, especially for those which have a material impact on the regulated entities. - Focus on regulatory convergence. The ESAs work should focus on regulatory harmonization to ensure that supervisory practices converge towards the most efficient and effective configuration. - Governance. To best promote and protect EU interests, the ESAs should have greater autonomy from NCAs. We support the establishment of Executive Boards comprised of independent, full-time members who are selected on their merits and competences. - Third Country Equivalence: The EBA should play a more prominent role in the equivalence process due to its level of expertise and have appropriate resources to develop this task. - Voting in the EBA: the double majority voting should be abolished as all Member States should have the single market (and not Eurozone) in mind when voting. - ESMA direct supervision of certain types of prospectuses. We have several doubts to support the Commission proposal that ESMA becomes the direct supervisor of certain prospectuses. NCAs deal with the supervision of prospectuses sufficiently and we are concerned that the proposals could hinder market efficiency. - Stakeholder’s involvement: It is necessary to balance Stakeholder Grups' composition in the direction of enhancing theirtechnical capability, to increase their usefulness in providing feedback to the ESAs. - Reporting Requirement : An alignment of reporting practices is highly desirable. - Funding: more public funding should be provided for the ESAs
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

14 Sept 2017 · CRR- CRD, Basel implications, PSD 2, Fintech

Meeting with Andrus Ansip (Vice-President) and

22 Jun 2017 · Digital Single Market, FinTech and innovation, cybersecurity

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

2 Jun 2017 · introduction of Center for Financial Education and Capabilities, Financial Education Summit

Meeting with Andrus Ansip (Vice-President) and

13 Mar 2017 · Cybersecurity, DSM mid-term review

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete) and Banco Santander, S.A.

3 Nov 2016 · Capital Union and it deliverability

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and Deutsche Bank AG and

10 Oct 2016 · CRR; CMU; TLAC

Meeting with Jonathan Hill (Commissioner)

10 Dec 2015 · Introductory Meeting and Digital Banking

Meeting with Günther Oettinger (Commissioner)

20 Oct 2015 · Digital Economy

Meeting with Eric Mamer (Digital Economy)

8 Apr 2015 · DSM

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

11 Feb 2015 · TTIP and Mexico

Meeting with Miguel Arias Cañete (Commissioner) and

11 Feb 2015 · Commission Working Programme and Digital Agenda

Meeting with Nathalie De Basaldua Lemarchand (Cabinet of Commissioner Jonathan Hill)

11 Feb 2015 · Introductory Meeting

Meeting with Jyrki Katainen (Vice-President) and

23 Jan 2015 · Investment plan

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen) and Deutsche Bank AG and

9 Dec 2014 · Investment initiative