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BlackRock

BLK

BlackRock is one of the world's leading providers of investment, advisory, and risk management solutions.

Lobbying Activity

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

9 Dec 2025 · Verbriefung

Meeting with Markus Ferber (Member of the European Parliament)

18 Nov 2025 · Securitization

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Nordea Bank Abp and

19 Sept 2025 · EU’s investment capacity in the context of SIU

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

11 Sept 2025 · Retail investment strategy

Meeting with Billy Kelleher (Member of the European Parliament)

14 Jul 2025 · Capital Markets Union

BlackRock urges flexible EU savings accounts with broad choice

8 Jul 2025
Topic — EU consultation on a blueprint for savings and investment accounts to boost retail market participation.
Message — BlackRock supports creating investment accounts that are simple, digital, and offer diverse investment options. They oppose mandatory holding periods or restricted product lists that could deter retail investors. The blueprint should prioritize easy tax integration and flexible monthly contribution models.12
Why — Including a wide range of products would increase demand for BlackRock's diverse investment funds.3
Impact — Tax authorities may face technical difficulties managing automated deductions and complex cross-border account portability.4
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Meeting with Pim Lescrauwaet (Cabinet of Commissioner Valdis Dombrovskis)

2 Jul 2025 · Discussion amongst senior policymakers and experts on Europe’s investment outlook in the current global context and Europe’s productivity agenda

Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque) and

2 Jul 2025 · Information exchange with representatives of the asset management industry.

Meeting with Johan Van Overtveldt (Member of the European Parliament)

24 Jun 2025 · Cryptocurrencies

Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

We welcome the Savings and Investment Union initiative that empowers citizens to invest in their future, channel capital into EU businesses and enhance the depth, effectiveness and connectivity of EU capital markets. Reflections on the future of the EUs supervisory framework must balance multiple objectives: improving market integrity and growth; appropriately protecting investors; and maintaining robust financial stability oversight. As such, adjustments to the existing supervisory framework must be proportionate, demonstrably support more integrated capital markets, and take care to not introduce new burdens or costs that could detract from the goal of fostering investment into the EU. Single supervision of European banks focuses on prudential capital leaving conduct issues to national supervisors. The asset management business model with third party custody of client assets does not pose the same prudential capital risk. Supervision of asset managers whatever their size should continue to focus on conduct at an entity level and on products where the EU already benefits from world-class national supervisory centres in the fund and asset management sector. We support measures to reinforce connectivity, standardisation, consistency and align practices but without rebuilding the existing supervisory architecture. A structural overhaul that splits supervision of management companies from product authorisation and oversight will not simplify supervision and is likely to undermine existing centres of excellence, creating additional layers of review and costs. A multi-year effort to enact significant changes to the supervisory architecture will divert political attention from more impactful measures to increased investment in the EU economy, and likely require significant upfront investment by industry, diverting resources from innovation and improving end-investor outcomes. Most of the current inefficiencies in supervision of EU capital markets stem less from the supervisory architecture and more from gold-plating and inconsistent interpretations of regulation at the national level. Aligning regulation and supervision are distinct goals, and challenges in one cannot be solved by altering the other. We see opportunities to enhance practices through stronger supervisory convergence, for example via more effective use of the existing supervisory convergence toolkit which is in many cases underused. We see benefit in reinforcing coordination forums such as supervisory colleges led by, and composed of, national regulators. Different configurations should be considered based on firms structures, product mix, and client base. For some firms, especially those with a multi-hub presence, a rotating chair model involving relevant NCAs may be most appropriate. Others with a clearly defined headquarters might benefit from a lead NCA approach. We recommend investing the finite resources of ESMA and NCAs in greater convergence and building common trust and confidence between NCAs. For the common rule book to converge in practice, we need a supervisory outlook with increased use of common supervisory actions and shared supervisory collaboration platforms. Emerging technologies such as the development of a standardised data reporting process and language, could help supervisors discharge their duties more effectively and would support the roll out of AI tools. Focus on interoperable regulatory data reporting platforms for use by firms, NCAs and ESMA would bring significant efficiency gains, especially in times of market stress, and reduce existing costs and inefficiencies. Common data reporting language and templates would assist firms from a burden reduction perspective and prioritise better data sharing between NCAs. Crucially, before decisions on more integrated supervision are made, we support the use of a pilot project to ensure decisions are made based on real-world evidence this will help inform prioritisation of supervisory convergence
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Meeting with Bernard Guetta (Member of the European Parliament) and Aviva Plc and

4 Jun 2025 · Discussion with global investors on the future of Europe

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

2 Jun 2025 · Exchange with asset managers on the integration of EU capital market

BlackRock urges flexible and simplified EU sustainable finance rules

30 May 2025
Topic — A review of EU rules to simplify sustainable finance disclosures.
Message — BlackRock recommends a flexible, principles-based framework and a transition category for investments. They suggest removing company-level disclosures and creating shorter reports for retail clients.123
Why — A simpler framework reduces the firm's administrative costs and complex reporting burdens.45
Impact — Civil society groups lose visibility into how financial firms manage overall sustainability impacts.6
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Meeting with Valdis Dombrovskis (Commissioner) and

29 Apr 2025 · Trade tensions and impact on global economy International role of the Euro Competitiveness of the EU economy, with special focus on the deepening of the Single Market; Capital Markets Union The EU’s intentions to step up defence spending

Meeting with Jozef Síkela (Commissioner), Jozef Síkela (Commissioner)

29 Apr 2025 · Private investments in the European Union

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur)

14 Apr 2025 · AI in Financial Services

Meeting with Maria Luís Albuquerque (Commissioner) and

3 Apr 2025 · Savings and Investment Union – asset management and growth capital

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

26 Mar 2025 · Exchange of views on the outcome of the EC consultation on macroprudential policies for NBFI.

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

Debt and equity are two primary ways businesses can raise capital, each with their own characteristics and implications. Making sure that both are viable options for startups and scale ups is the starting point in encouraging a dynamic ecosystem. There is no one size fits all approach much depends on the business model and appetite for external participation from founders and managers of the companies. When assessing possible avenues for financing venture and growth capital (V&GC), EU policymakers should seek to enable a range of financing options for early-stage companies. Private debt is a natural match for young companies, which may still be founder-owned, want to remain privately held but who do not have direct access to public market financing through bond issuance and need capital to finance innovation. Direct lending is typically equity funded by long-term buy-and-hold investors, which aligns with investees longer term capital commitments. When facilitated through investment funds, these vehicles are typically closed-ended and subject to regulatory reporting and controls on leverage and liquidity risk management under AIFMD requirements.The lack of scale in EU V&GC markets will not be resolved by legislative changes to investment vehicles or expending political capital to design a 28th regime. The real challenge is that these markets are national; a single market has not emerged at EU level. We recommend a focus on creating better cross-border visibility of investment opportunities both in terms of investible opportunities and investors themselves. In this way Europe can foster innovation and economic growth, deepening EU markets and crowding-in non-EU investment. The main driver of success in EU V&GC markets is a managers transaction experience and local EU presence, given companies prefer to work with lenders who can navigate regional complexities. These markets are relationship-driven with little intermediation and few auction processes. Developing ongoing relationships between sponsors, PE firms and investee companies takes time, but is a vital component in the ecosystem. Europe would benefit greatly from efforts to provide better visibility of investible opportunities in other Member States (MS) through the creation of a common platform for private markets. EU V&GC markets are also deeply reliant on sponsor relationships, and in-depth knowledge of the many different local ecosystems, legal jurisdictions and key market participants (e.g. lawyers, accountants, administrators). Its much harder for new or non-European players to gain a meaningful foothold, which in turn limits the pool of lenders available to young EU companies. With respect to fund vehicles, we encourage policy makers to consider the potential of the recently updated ELTIF regime to channel long-term investment into various sectors including SMEs, real estate and infrastructure. They offer a broader investment scope compared to EuVECA, which is primarily focused on VC. The EuVECA AUM cap has naturally attracted smaller managers, while ELTIFs are increasingly attractive to more scaled-up operators. The increasing scale of ELTIFs makes them more attractive to a broader range of investors, including institutional investors looking for diversified and long-term investment opportunities. ELTIFs also benefit from a more harmonised regulatory framework across the EU, which facilitates cross-border investments and reduces the administrative burden for fund managers by not having to comply with two different compliance regimes. Finally, while it could be interesting to explore the feasibility of introducing a 28th regime for smaller companies (e.g. with common rules on insolvency, accounting and reporting, tax, company law), the regime will only succeed if MS, especially national tax authorities, agree to recognise its pan-European status. Otherwise, a 28th regime risks adding another layer of complexity or even becoming redundant from the outset.
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Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and Accountancy Europe

12 Mar 2025 · Omnibus I

BlackRock urges EU to prioritize household participation in capital markets

7 Mar 2025
Topic — New EU policy framework for connecting savings to investment and economic growth.
Message — BlackRock requests the creation of individual investment accounts with stable tax incentives and simplified advice rules. They want clear frameworks for fractional trading and private market access through retirement accounts. They recommend a tailored supervisory approach rather than centralized oversight.123
Why — This would expand their retail client base and reduce supervisory compliance costs.456
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Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

7 Mar 2025 · Savings and Investments Union

Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union), Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and

20 Feb 2025 · Capital Markets Union (CMU) and Saving and Investment Union (SIU), with a focus on long-term savings accounts, the Non-Bank Financial Intermediation (NBFI) agenda, and the review of the UCITS Eligible Assets Directive.

Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Fleishman-Hillard and

20 Feb 2025 · CMU discussion with asset management industry

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

6 Feb 2025 · Exchange with BlackRock on CMU and SIU

Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Institutional Money Market Funds Association

15 Jan 2025 · Macroprudential Polices for NBFIs

Meeting with Regina Doherty (Member of the European Parliament)

15 Jan 2025 · CMU

Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

14 Jan 2025 · The development of a European market for retirement savings

Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

14 Jan 2025 · Retirement market discussion

Meeting with Gert Jan Koopman (Director-General Enlargement and Eastern Neighbourhood)

10 Jan 2025 · Developments in Ukraine’s Capital Markets

Meeting with Billy Kelleher (Member of the European Parliament)

18 Nov 2024 · Asset management

Meeting with Rasmus Andresen (Member of the European Parliament, Shadow rapporteur)

15 Oct 2024 · FiDA, CMU

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness) and

19 Jun 2024 · Capital Markets Union

Meeting with Gert Jan Koopman (Director-General Enlargement and Eastern Neighbourhood)

28 May 2024 · Initiative of establishing the Ukraine Development Fund

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and BNP PARIBAS and

22 Feb 2024 · Retail investment Strategy

Meeting with Ondřej Kovařík (Member of the European Parliament, Shadow rapporteur) and Société Générale and

21 Feb 2024 · FIDA

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Deutsche Bank AG and

29 Nov 2023 · Energy transition

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

29 Nov 2023 · CMU, development of non-bank finance

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

28 Nov 2023 · Exchange on capital markets in the EU.

Meeting with Ralf Seekatz (Member of the European Parliament, Shadow rapporteur) and Deutsche Börse AG and Verbraucherzentrale Bundesverband

24 Oct 2023 · Kleinanlegerstrategie

Meeting with José Manuel García-Margallo Y Marfil (Member of the European Parliament, Shadow rapporteur)

26 Sept 2023 · ESG Ratings Regulation

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

16 May 2023 · Net Zero Industry Act

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

21 Mar 2023 · Sustainable finance; Net Zero Industry Act; Hydrogen Bank

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Allianz SE and

15 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Ondřej Kovařík (Member of the European Parliament) and State Street Corporation

14 Mar 2023 · Retail Invest Strategy

Meeting with Daniel Freund (Member of the European Parliament)

13 Mar 2023 · Blackrock corporate social responsibility (CSR)

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and AMUNDI AM and

20 Feb 2023 · Consolidated tape, MiFIR

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and State Street Corporation and Institutional Money Market Funds Association

16 Nov 2022 · Capital Markets Union, MMFs

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

26 Oct 2022 · Retail Strategy & Sustainable Investment

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness) and

26 Oct 2022 · EMEA Asset Management CEOs to discuss retail investor engagement as well as ESG/sustainable finance. Cab EVP Dombrovsksi also participated Andrea Beltramello.

Meeting with René Repasi (Member of the European Parliament, Rapporteur for opinion)

14 Oct 2022 · EU-Lieferkettengesetz (CSDD)

Meeting with Esther De Lange (Member of the European Parliament) and Allianz SE and Invesco Management SA

10 Oct 2022 · MiFIR/D - APA

BlackRock Urges Financial Sector Exemptions from Sustainability Rules

23 May 2022
Topic — The EU seeks to mandate corporate due diligence for human rights and environmental standards.
Message — BlackRock supports the framework but urges a distinction between investors and operational companies. They recommend exempting investment funds to avoid regulatory conflicts.12
Why — This exemption prevents overlapping regulations and reduces the complexity of monitoring assets without direct control.3
Impact — External stakeholders lose access to information because investors lack direct contractual ties with companies.4
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

1 Apr 2022 · Videoconference - Commission priorities to deliver Capital Markets Union (CMU)

Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur) and Allianz SE and

9 Mar 2022 · MiFIR Review and CMU Package

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

17 Jan 2022 · Videoconference - Exchange of views on tax policies and sustainable finance

Meeting with Maarten Verwey (Director-General Economic and Financial Affairs)

8 Jul 2021 · Virtual Roundtable Discussion on "The European Labour Market: The Impact of the COVID-19 Pandemic"

Meeting with Axel Voss (Member of the European Parliament, Rapporteur)

10 Jun 2021 · AI and Finance

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness), Claude Bocqueraz (Cabinet of Commissioner Mairead Mcguinness) and

26 May 2021 · Retail investment

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and JPMorgan Chase & Co. and

25 May 2021 · EU UK regulatory cooperation in financial services

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

BlackRock is pleased to have the opportunity to respond to the consultation on the draft technical screening criteria for the first two environmental objectives related to the EU taxonomy. BlackRock supports the EU’s efforts to build the taxonomy framework, and we welcome the draft criteria as an important milestone in its longer-term development. Please see supporting document for detailed commentary.
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Response to Long Term Investment Funds – Review of EU rules

14 Oct 2020

BlackRock welcomes the recommendations of the High Level Forum on Capital Markets Union (HLF) on the ELTIF as well as the European Commission’s calls in the CMU Action Plan to promote the ELTIF. In addition to the HLF recommendations we note some additional, incremental changes which we believe will be beneficial. 1. Changes and clarifications to investment rules • Investment in other alternative investment funds - the ELTIF rules impose a blanket restriction on investment in other funds throughout the fund’s life. In practice this has proved unduly restrictive for as (1) Fund of fund structures are a common and effective way of obtaining exposure to private assets; and (2) in the context of fully paid-in capital structures, the ability to invest on a broader basis in other funds (at least during portfolio ramp-up) would allow for a faster deployment of capital. • We support increased exposure to public market assets in specific circumstances, for example, during the ramp up period provided that this does not detract from the ELTIF’s fundamental role of providing long term returns and investment into long term EU assets. We believe it remains important to retain a clear distinction between UCITS and ELTIFs. • Investment in real assets: ELTIF managers would benefit from more practical guidance concerning the eligibility of certain real asset investments, i.e. what assets could be considered “integral to, or an ancillary element of, a long-term investment project that contributes to the Union objective of smart, sustainable and inclusive growth”. • Further guidance and case studies regarding the general concept of “benefit to the European economy”. In particular, we recommend providing greater clarity around the extent to which an ELTIF can be constructed with a focus outside of the EU, noting that investment in third countries can also bring capital to ELTIFs and thereby benefit the European economy (as per Recital (4) of the ELTIF Regulation). Minimise local regulatory requirements • Despite the ELTIF regime having direct effect in each member state, a number of national competent authorities have in practice imposed additional local requirements for distribution to retail investors. • Satisfying multiple cross-jurisdictional marketing registration and notification procedures substantially increases time to market, costs for investors and burden on fund sponsors. We recommend disallowing the imposition of additional local rules. The ELTIF application (which is itself shared with local regulators) should be deemed sufficient to begin distributing the product in each jurisdiction. Encourage wider recognition of ELTIF through mutual recognition or tax agreements • Article. 11 of the ELTIF regulation provides that an ELTIF may invest in countries outside of the EU, provided that such countries have certain tax transparency / information sharing agreements with every EU country in which the ELTIF is marketed. As noted above Recital 4 of the ELTIF Regulation notes there are potential benefits to the European economy from such investment. Therefore, if an EU country in which an ELTIF is marketed does not have such agreements in place with a certain third-country jurisdiction, then the ELTIF may not acquire assets in such a third country jurisdiction (and vice versa). • In practice, this forces managers in some cases to either restrict their marketing, or otherwise restrict their investment strategy. We encourage the wider recognition of ELTIF in relevant recognition or tax agreements. Additional areas where further clarity/guidance required • “Equal treatment of investors”. The “no preferential rights” principle is highly restrictive and the lack of clarity on how it should be applied can lead to unnecessarily burdensome share class mechanisms. • Employee investment: even if employees are technically ‘retail investors, co-investment by knowledgeable employees should be subject to a simplified take on procedure.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

13 Mar 2020 · CMU, Sustainability and Fund regulation

Meeting with Reinhard Felke (Cabinet of Commissioner Pierre Moscovici) and Allianz SE and

21 Nov 2018 · Economic outlook; European Semester package; future of EMU

Meeting with Valdis Dombrovskis (Vice-President) and

23 Apr 2018 · EU-US regulatory cooperation, Sustainable Finance, Brexit

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

1 Mar 2018 · Green Finance

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

1 Dec 2017 · Introductory remarks and roundtable with EU financial industry and AFISMA/European Chamber of Commerce on financial reforms and banking union

Meeting with Valdis Dombrovskis (Vice-President) and Afore Consulting and

30 Nov 2017 · Speech at EU-Asia Financial Services Dinner Reception on growth and investment in Europe; Fintech and sustainable finance

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

9 Nov 2017 · CMU, sustainable finance, AIFMD

Meeting with Valdis Dombrovskis (Vice-President) and

14 Oct 2017 · CMU, ESAs review, sustainable finance

Response to Further amendments to the European Market Infrastructure Regulation (EMIR)

17 Jul 2017

Implications of a location policy on end-investors The Commission has proposed a two tier approach to supervision of CCPs under the EMIR 2.0 proposals. We are encouraged that these do not include automatic relocation triggers for Euro-clearing – but there are provisions for ESMA and the ECB to be able to recommend relocation to the Commission, and with it implement a introduce CCP location policy. The following remarks address this residual possibility. 1. Market fragmentation The present system allows for the free flow of currencies through an unrestricted choice of CCPs which plays an important role in a global system of cross-currency netting, with corresponding reduced costs, the benefit of which is felt by end-investors. By contrast, a location policy would structurally fragment the global market, splitting a less liquid on-shore market in the Eurozone from a more liquid offshore market outside of the Eurozone. With the onshore market no longer able to offset against the positions of the offshore market, netting efficiencies would decrease and reflecting the increased risk in the system, margin costs would increase dramatically. These risks and costs would be passed on to clients of the clearing brokers and ultimately to the end-users of derivatives - Europe’s pensioners, savers and companies. 2. Risk concentration We anticipate that there will be fewer EU and UK banks providing clearing member services, not only due to possible additional costs of capital. Risk will most likely become increasingly concentrated in fewer larger counterparties (over which EU authorities will have limited day-to-day and macro-prudential oversight), with potential implications for financial stability from this point forward. Location policy will only accelerate this trend with fewer banks supporting multiple shallower and more costly liquidity pools. Location policy also has important implications for the global CCP resilience, recovery and resolution agenda. With fewer clearing members supporting fewer CCPs, loss mutualisation in the event of a CCP failure would become even more constrained. Fewer default resources imply a higher probability of CCP resolution and with it a greater likelihood of tax payer bail out in the most severe forms of market stress. Increasing systemic risk caused by weakening the default management process would be a very real unintended consequence of the implementation of a location policy and a threat to the G20 objective of delivering a more robust clearing environment for OTC derivatives by broadly requiring central clearing. 3. Global implications and precedent Pursuit of location policy would have global implications, the impact of which would be felt by end-investors in the EU in the longer term. Euro location requirements would set a precedent for currency clearing elsewhere in the world. It would mark a break from international norms and would likely provoke retaliatory measures – particularly damaging to global markets and the international consensus if pursued by the United States. Recommendations: The European Commission issues detailed and imperially evidenced economic impact assessment of the projected costs and benefits from the forced re-location of CCPs should they be deemed to be substantially systemic institutions. Additional time is taken to carefully consider alternatives to CCP location policy, given the global implications of such a move from financial stability perspective. This time should be used to fully explore how incentives between how the competent authorities of EU and 3rd country regulators could be aligned so that co-decision, rather than co-operation, becomes the default approach to supervising systemically significant institutions. The bar to relocation is raised to avoid automatic and immediate triggers to a location policy and extra safeguards are built into the process which fully evidence the impact of triggering a location policy.
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Response to Review of the appropriate prudential treatment for investment firms

19 Apr 2017

The current CRD/CRR regime which is primarily designed to mitigate the risks to shareholders and taxpayers of inappropriate risk taking within banking entities, neither sufficiently takes into account the different risk profiles of other investment firms nor reflects the many other risk mitigants which currently exist in the European regulatory capital regime. This has resulted in a regulatory regime that does not recognise the agency business model of many investment firms such as asset managers. BlackRock supports the aims of the European Commission in designing a new prudential regime for investment firms, which provides appropriate incentives to mitigate risk and a more effective use of capital. In addition, we support the general aim of developing a prudential regime that has rules appropriately tailored for investment firms in general, and asset managers in particular, rather than relying on a "one-size-fits-all" set of rules originally designed to apply to banks We recognise that other investment firms have different business models and risk profiles. While there is value in setting out a minimum set of requirements to consider across all investment firms, it is also important to note that not all factors will be relevant to asset managers and other firms that are structured on an agency basis. A proportionate approach is needed that permits firms to avoid applying factors that are not relevant to their business model and thereby avoid creating unnecessary complexity. We set out more detailed comments in the attached letter.
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

22 Nov 2016 · Sustainable/Green Finance, CMU

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

8 Nov 2016 · Sustainable/ Green finance in CMU

Meeting with Valdis Dombrovskis (Vice-President) and

8 Oct 2016 · CMU; EFSI

Meeting with Mette Toftdal Grolleman (Cabinet of Vice-President Valdis Dombrovskis)

7 Sept 2016 · Macroprudential; CMU; Personal Pensions

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

29 Feb 2016 · Tax Avoidance Package

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

29 Feb 2016 · TAX, OECD-BEPS

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

29 Feb 2016 · Investment Fund Taxation

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

17 Feb 2016 · European economic outlook and economic governance agenda

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

20 Oct 2015 · European Fund for Strategic Investments, and the Capital Markets Union

Meeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)

13 Oct 2015 · Financial Services Policy

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

1 Oct 2015 · Investment plan + infrastructure investments

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

10 Sept 2015 · Credit information on SMEs, ELTIFs, Securitisation and Solvency II.

Meeting with Jack Schickler (Cabinet of Commissioner Jonathan Hill) and Fidelity International and

24 Aug 2015 · CCP recovery and resolution

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

23 Jun 2015 · CMU, Macro Prudential issues in Non-Banking

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

19 May 2015 · Capital Markets Union

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

9 Apr 2015 · Money Market Funds

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

1 Apr 2015 · EFSI and capital markets union

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

20 Mar 2015 · BEPS project

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

20 Mar 2015 · BEPS

Meeting with Jonathan Hill (Commissioner)

27 Feb 2015 · EU and US Regulatory Agenda in Financial Services

Meeting with Jonathan Hill (Commissioner)

27 Jan 2015 · ELTIF, CMU

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

27 Jan 2015 · CMU

Meeting with Valdis Dombrovskis (Vice-President) and

27 Jan 2015 · CMU

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

3 Dec 2014 · Investment Initiative

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

3 Dec 2014 · Investment initiative