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Commerzbank AG

Commerzbank is a leading international bank with operations in over 50 countries, specializing in retail, corporate and investment banking.

Lobbying Activity

Meeting with Estelle Goeger (Cabinet of Executive Vice-President Stéphane Séjourné) and Bundesverband der Deutschen Industrie e.V. and

4 Nov 2025 · Overview of the Commission's Single Market Strategy.

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

18 Sept 2025 · SIU or Sustainable Finance

Meeting with Markus Ferber (Member of the European Parliament)

1 Sept 2025 · RIS, SIU, Securitisation and Simplification

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

1 Sept 2025 · Securitization Package, SIU and Simplification (FiDA).

Meeting with Gabriele Bischoff (Member of the European Parliament)

17 Jul 2025 · Austausch mit Konzernbertriebsrat

Meeting with Matthias Ecke (Member of the European Parliament)

16 Jul 2025 · Bankenregulierung - Sicht des Betriebsrats

Meeting with Dennis Radtke (Member of the European Parliament)

8 Jul 2025 · Fusion Commerzbank/UniCredit

Meeting with Peter Liese (Member of the European Parliament)

26 Jun 2025 · Austausch

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

5 Jun 2025

We strongly support the objectives of the EU Savings and Investment Union as an important tool to close the significant funding gaps we are facing. Against this backdrop, we welcome the opportunity to share our views on how more integrated and efficient EU capital markets can be achieved. Our recommendations focus on measures required to support retail participation, increase the use of DLT, simplify tax handling, and strengthen the securitization market. To increase retail participation in capital markets, there is need for leaner information requirements and the creation of an investment culture. The proposed measures in the context of the Retail Investor Strategy and the European Retail Savings Label should be accompanied by the creation of a permanent European Commission Market Expert Group to provide practitioners perspective on implementation efforts consistently throughout the legislative process. To support the uptake of DLT, widening the scope of the DLT pilot regime and working towards better recognition wholesale CBDC solutions would be necessary. With regards to taxes, the debt-equity bias remains a barrier to capital markets integration as are withholding tax regulations for cross-border investments. FASTER is an important contribution to the harmonization of withholding tax in the EU. After implementation in the member states by 2030, an evaluation should follow to assess the effectiveness of the measures. Securitization is a key tool to enhance capital flow into the real economy, and it has been encouraging to see how the SIU strategy unveiled the need for a stronger European securitization market. A stronger market will allow banks to free up capital and create additional capacity to lend to the economy. Although no silver bullet will revive the EU securitization market, several targeted amendments to the regulatory framework will strengthen Europe´s competitiveness. Capital requirements for securitizations should be targeted to the risk profile, complexity and scope of the securitization. Equally, reporting and due diligence requirements should account for the different information needs and be more risk-sensitive, tailored towards the risk profile of the different market segments and asset classes.
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Meeting with Ralf Seekatz (Member of the European Parliament)

3 Jun 2025 · Allgemeiner Austausch

Meeting with Marlene Rosemarie Madsen (Cabinet of Executive Vice-President Henna Virkkunen)

2 Jun 2025 · Simplification and coordination between financial services and digital horizontal legislation

Meeting with Valdis Dombrovskis (Commissioner) and

2 Jun 2025 · Simplification

Meeting with Maria Luís Albuquerque (Commissioner) and

2 Jun 2025 · Exchange on developments in financial services

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

27 May 2025 · Commerzbank’s use of cloud services and on the Commission’s ongoing initiatives (e.g. Cloud and AI development Act, revision of CSA)

Meeting with Rasmus Andresen (Member of the European Parliament) and Deutsche Bank AG and

9 Apr 2025 · SIU

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

17 Mar 2025 · Banking issues

Meeting with Svenja Hahn (Member of the European Parliament) and Microsoft Corporation and

14 Feb 2025 · Exchange on upcoming digital EU legislation

Meeting with Dennis Radtke (Member of the European Parliament)

13 Nov 2024 · Arbeitnehmerechte & Fusion

Meeting with Mairead McGuinness (Commissioner) and

10 Sept 2024 · High-level executive roundtable: preventing the circumvention of EU sanctions on sensitive goods.

Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

10 Sept 2024 · Preventing the circumvention of EU sanctions on sensitive goods

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

25 Oct 2023 · Capital Markets Union

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

25 Oct 2023 · Capital Markets Union, Digital Euro, Transition Finance

Meeting with Stephanie Riso (Director-General Budget)

4 May 2023 · Update on DG BUDG strategy and priorities for the upcoming months

Meeting with Joachim Schuster (Member of the European Parliament)

27 Mar 2023 · Banking regulation

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

8 Mar 2023 · Corporate Sustainability Due Diligence

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

27 Feb 2023 · CRR3 (staff)

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

1 Feb 2023 · Retail Investment Strategy

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

16 Nov 2022 · Securitisation

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

16 Nov 2022 · Transparent and standardised securitisation

Meeting with Joachim Schuster (Member of the European Parliament)

25 Oct 2022 · Annual reception

Meeting with Reinhard Bütikofer (Member of the European Parliament) and Critical Raw Materials Alliance

8 Sept 2022 · Exchange of views

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen) and Banco Santander, S.A. and

7 Jul 2022 · Topic: Polish loans in foreign currency (CHF) and the UCTD Directive. Eu Commission made it clear that we do not interfere in cases before the ECJ and with the SJ work in this regard.

Meeting with Joachim Schuster (Member of the European Parliament) and Deutsche Bank AG and

21 Jun 2022 · Banking package

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur) and Nederlandse Vereniging van Banken / Dutch Banking Association

14 Jun 2022 · CRR (staff)

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

25 Mar 2022 · ETS Revision

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

17 Mar 2022 · Payment for Order Flow (PFOF) MiFIR review

Response to Long Term Investment Funds – Review of EU rules

9 Mar 2022

Commerzbank`s subsidiary CommerzReal has launched the ELTIF “KlimaVest” in 2021. The overarching goal in setting up an ELTIF as an impact fund investing in renewable energies investments for retail clients was to offer those investors the opportunity to benefit from attractive returns resulting from illiquid investments while making those investments redeemable on a daily basis by granting redemption rights. We believe in times of zero or even negative interest rates, this kind of investments should not only be offered to institutional investors – provided an appropriate level of investor protection can be maintained. We commend the Commission for proposing to eliminate the minimum investment of 10.000 EUR and to lift the requirement to have free disposable investment funds of at least 100.000 EUR. In our view, these requirements have to be lifted to enable retail investors beyond the private wealth segment to invest into an ELTIF. However, we do not deem these two changes as sufficient to invigorate ELTIF as an investment vehicle. The proposed new ELTIF regulation envisages to drop the requirement to render investment advice to retail clients while keeping the obligation to perform a suitability assessment before marketing ELTIF units to retail investors. This entails the collection of information under Article 25 MiFID, i.e. investor’s knowledge, competence, financial situation, investment objectives, including the ability to bear losses and risk tolerance. A report on the assessment has to be made available to the investor generally (there are exemptions for distance transactions) in advance of the transaction on a durable medium. We believe that this is not a relief for distributors leading to an acceleration of ELTIF distribution to retail investors. In our view, a considerable increase of distribution to retail investors may only be achieved if the suitability assessment is not required. In our view (which we have sounded with distributors), from an operational perspective, the performance of the suitability assessment is still not possible: Retail distribution operations are set up for mass transactions and therefore highly standardized from an IT-perspective. They are designed for “execution only products”. Each deviation from established (IT)processes leads to reluctance of distribution agents to onboard a new product (such as the ELTIF). In addition, to perform a suitability assessment and to establish, process and render the necessary documents to the investor is a costly operation for a distributor. To cover the cost with the fees earned a distributor will likely not offer an ELTIF to retail clients investing less than about € 6.000. Which means that the obligation to perform a suitability assessment will impede retail distribution. Taking into account the proposed changes to the ELTIF regulation in their entirety, i.e. waiving the entry ticket, introducing a “liquidity window” for exits before the funds maturity and emphasizing the fact that the ELTIF is a well regulated transparent investment vehicle we believe the performance of a suitability assessment is not necessary to guarantee an adequate investor protection. Retail investors can adequately be protected by making available redemption rights. As stated in the Explanatory Memorandum, the ELTIF should not be subject to stricter rules than the distribution of other complex financial products (such as securitizations or subordinated eligible liabilities). The German legislator applied the same rationale but decided to declare investment schemes such as the open ended property fund and the open ended infrastructure investment fund “execution only”. In our view, the (qualitative) suitability assessment would turn out to be an insurmountable new threshold for investments in ELTIFs. The removal of the quantitative thresholds would thus become ineffective. The ambition to increase retail distribution would in our view not be reached.
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Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

3 Mar 2022 · CRR (staff)

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

25 Jan 2022 · BU and CMU

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

30 Nov 2021 · Green and digital transitions, competitiveness of EU banking sector.

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

30 Nov 2021 · Green and digital transitions, competitiveness of EU banking sector

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

27 Oct 2021 · CH Libor and on the implementation of Basel III

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

20 Sept 2021 · Situation of the EU banking sector, sustainable finance

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

7 Sept 2021 · Basel III implementation; sustainable finance; retail investment

Meeting with Gert Jan Koopman (Director-General Budget)

6 Sept 2021 · Next Generation EU

Response to Designation of a statutory replacement rate for CHF LIBOR (Benchmarks)

23 Aug 2021

We welcome the European Commission's initiative to establish a statutory replacement rate for CHF LIBOR and support the draft Implementing Regulation in its entirety. The statutory replacement rate will prevent serious disruption in financial markets that would otherwise occur following the cessation of CHF LIBOR publication. In our view, the replacement outlined in the EC consultation (SARON compounded under last reset methodology plus adjustment spread) is the best solution. This is further supported by the fact that the last reset method is consistent with the SNWG recommendation. We want to emphasize that the Implementing Regulation needs to be finalized as soon as possible – at the latest by end of September 2021. It is important to have legal certainty before the start of Q4 2021.
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Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

27 May 2021 · Sustainable corporate governance

Meeting with Gert Jan Koopman (Director-General Budget)

20 Nov 2020 · EU SURE instrument

Meeting with Frans Timmermans (Executive Vice-President) and Assicurazioni Generali S.p.A and

8 Sept 2020 · Green recovery: Financing of the Green Deal

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

16 Jun 2020 · MiFID II review

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and Banco Santander, S.A. and

22 Feb 2019 · Polish financial services legislation

Meeting with Günther Oettinger (Commissioner)

24 Sept 2018 · MFF

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

28 Feb 2018 · EMIR

Meeting with Valdis Dombrovskis (Vice-President) and

11 Jan 2018 · Monetary Issures; EMU; Basel III

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

15 May 2017 · EBA draft RTS on Strong Customer Authentication and Secure Communication

Meeting with Günther Oettinger (Commissioner)

16 Nov 2016 · digitisation in the geopolitical context

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

14 Nov 2016 · Retail Financial Services

Meeting with Markus Schulte (Digital Economy)

1 Jul 2016 · Digitisation in banking

Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill)

31 May 2016 · Agenda regarding financial services

Meeting with Günther Oettinger (Commissioner)

31 May 2016 · banking in digital era

Meeting with Günther Oettinger (Commissioner)

2 May 2016 · Datensicherheit und Banken

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)

19 Oct 2015 · Data Protection

Meeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)

19 Oct 2015 · Financial Services Policy

Meeting with Michael Hager (Digital Economy)

15 Oct 2015 · banking and DSM

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

30 Sept 2015 · Better regulation in the area of financial services legislation; general questions on the portfolio

Meeting with Jonathan Hill (Commissioner)

28 Sept 2015 · Overview on Financial Regulation

Meeting with Jonathan Hill (Commissioner) and General Electric Company and

21 Sept 2015 · Financial Services Policy

Meeting with Markus Schulte (Digital Economy)

1 Sept 2015 · DSM

Meeting with Cecilia Malmström (Commissioner)

1 Sept 2015 · TTIP - "She VIP lunch"

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

23 Apr 2015 · IFRS

Meeting with Markus Schulte (Digital Economy)

20 Mar 2015 · Digital Single Market

Meeting with Günther Oettinger (Commissioner)

28 Jan 2015 · Bank reform, capital single market

Meeting with Jonathan Hill (Commissioner)

27 Jan 2015 · BSR, TLAC, CMU

Meeting with Martin Selmayr (Cabinet of President Jean-Claude Juncker)

27 Jan 2015 · Current Financial Issues

Meeting with Valdis Dombrovskis (Vice-President) and

27 Jan 2015 · Banking Union

Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill), Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

2 Dec 2014 · Structural Reform