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Credit Suisse Group AG

CSAG

Credit Suisse is a leading wealth manager with strong global investment banking and asset management capabilities.

Lobbying Activity

Meeting with Mairead McGuinness (Commissioner) and

21 Sept 2022 · Energy derivatives market

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

5 Nov 2021 · CRR, Basel III

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 Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic)

10 Sept 2020

We agree with the Commission that the MiFID unbundling rules were just one of the factors that resulted in less research on SMEs. In our view, SME research coverage would probably increase if there were a better likelihood of it being profitable. It is proportionately more expensive, and therefore riskier, to cover a company with a smaller number of less expensive shares in circulation, so rebundling research and trading in the shares of those smaller companies could help, to a certain extent. Academic research and our experience of financial markets show that increasing research coverage generally leads to greater liquidity- we enclose in that context a note that our then chief European economist wrote at the time the unbundling rules were being drafted. Although the note is written from the point of view specifically of fixed income markets, the point about decreased availability of information leading to lower liquidity is a general one. We agree with the Commission that the unbundling rules do not make sense for FICC markets: they are principal markets, there is no commission that needs to be unbundled and bid-offer spreads depends on factors other than the provision of research to a counterparty (e.g. cost of capital, cost of hedging, size of the security and size of the market, etc)- further details are discussed in the enclosed paper. Every bank needs to manage its capital and its treasury, and for this the input of research analysts in fixed income instruments and macroeconomics is crucial. Input from those researchers is key to the decisions taken by various trading desks of the bank, especially those that trade on a principal basis, taking risks on behalf of the bank. They service many other business areas as well as institutional clients. Having some in-house fixed income and macro economic research capability and expertise is a necessary aspect of being a bank, much like having a properly staffed compliance department. Both are fixed costs of being bank and being active in certain markets. Obliging investment firms to pay for FICC and macro research increased not only compliance costs but also the fees required to obtain research. As had been widely forecast, bid-offer spreads did not change- nor could they have done, since payment for research was not one of the factors affecting them. The Commission’s approach of focussing the scope of unbundling rules to financial instruments that trade on a commission basis is therefore not only correctly concentrated on the investor protection risks, but would also remove unnecessary red tape and costs, thus releasing resources, as well as, crucially, increasing the availability of research on FICC and on macroeconomic matters. There is great variability in approaches and business models. In Credit Suisse, we argued as far back as 2014 that we thought the market would benefit if macro research remained broadly available and, consistently with that belief, we make our macro research available free of charge to all investment firms that wish to receive it, in accordance with the relevant ESMA Q&A. This approach works well for written research, but we do think there would be further benefit to the market if economists were able to discuss the research freely. The Commission’s policy aims would be well-served by focussing article 13 on research and payments on equity transferable securities as defined in paragraph (a) of Article 4(1)(44) of Delegated Directive 2014/65/EU. It was a desire to bring transparency to the apportionment of commission payments that led to the art. 13 unbundling regime, so it is right that it should apply to equity transferable instruments, such as shares, that trade on a commission basis. It is key that the lighter regime for SMCs be available, rather than compulsory, for those research consumers and providers who are active in markets where it makes sense while not compelling the entire EU research ecosystem to incur the cost of such change.
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

4 Mar 2019 · ring-fencing

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

18 Dec 2018 · Banking 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 Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

25 Oct 2017 · cross-border financial services

Meeting with Dominique Ristori (Director-General Energy)

13 Oct 2017 · Clean Energy package

Meeting with Karmenu Vella (Commissioner) and

23 Feb 2017 · Blue economy financing, ocean energy

Meeting with Heinz Zourek (Director-General Taxation and Customs Union) and Swiss Finance Council

23 Feb 2015 · Current Taxation issues and EU-Swiss dossiers