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Deutscher Sparkassen-und Giroverband

DSGV

The German Savings Banks Association represents 343 savings banks, five state banks, and other financial services companies in the Sparkassen group.

Lobbying Activity

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

15 Jan 2026 · EU Banking Competitiveness: Policy & Progress

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

8 Jan 2026 · Savings and Investment Union (SIU) Strategy

Meeting with Markus Ferber (Member of the European Parliament)

6 Nov 2025 · Competitiveness in the EU banking sector

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

5 Nov 2025 · Competitiveness of European banks and functioning of regulatory framework

Meeting with René Repasi (Member of the European Parliament)

4 Nov 2025 · Digital Euro

Meeting with Daniel Caspary (Member of the European Parliament)

4 Nov 2025 · Austausch

Meeting with Jutta Paulus (Member of the European Parliament)

4 Nov 2025 · Finanzpolitik Rheinland-Pfalz

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

4 Nov 2025 · Digital Euro

Meeting with Angelika Niebler (Member of the European Parliament)

4 Nov 2025 · EU Digital Euro

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

4 Nov 2025 · Digital Euro

Meeting with Aliénor Margerit (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

14 Oct 2025 · Exchange of views on the proposal for the European Competitiveness Fund

German Savings Banks warn against uniform European investment accounts

4 Jul 2025
Topic — This consultation seeks a European blueprint for savings and investment accounts based on best practices.
Message — The DSGV wants the Commission to collect national examples rather than creating a single European model. They call for broad investment choices, no deposit limits, and easier advice rules for small investors.123
Why — Maintaining national control allows them to avoid costly restructuring to meet new EU-wide standards.4
Impact — Cross-border investors lose the benefits of a harmonized market with standardized investment rules.5
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Meeting with Maria Luís Albuquerque (Commissioner) and

26 Jun 2025 · Savings and Investment Union (SIU): improving access to capital market products, supporting long-term wealth creation and strengthening retirement planning

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

11 Jun 2025 · Financial data access framework (FIDA)

Meeting with Markus Ferber (Member of the European Parliament)

10 Jun 2025 · CMDI

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

10 Jun 2025 · PRIIPs VO

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

2 Jun 2025 · Exchange of views on the reform of the bank crisis management and deposit insurance framework (CMDI review)

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

9 Apr 2025 · SIU

Meeting with Angelika Chomicka (Cabinet of Commissioner Andrius Kubilius)

7 Apr 2025 · Role of the private banking sector to better support the security and defence industry

Meeting with Valdis Dombrovskis (Commissioner) and

17 Mar 2025 · Savings and Investment Union

Meeting with Michael Wimmer (Director Secretariat-General)

5 Mar 2025 · To discuss the Commission’s simplification agenda and explore possible approaches for constructive contributions from the financial sector.

Response to Savings and Investments Union

27 Feb 2025

The SIU should build upon the current discussions for simplification and the reduction of bureaucracy. The customer journey needs to be less burdensome to realize the benefits of capital markets for wealth creation and retirement planning. We need bold measures to reduce unnecessary regulatory requirements that make investments burdensome and time-consuming. For example, 69.1 percent of clients surveyed in a 2019 study by Ruhr University Bochum stated that they felt the time required to carry out their securities transactions was too high. This puts many clients off taking the step towards the capital market. Another problem is the information overload. Many clients feel overwhelmed by the amount of information. The choice between commission-based and fee-based advice models must be maintained. Especially young and unexperienced persons need support by advisors. A ban on certain types of investment advice would contradict the idea to attract more people to capital market investments. A simplified advisory process for basic investment products could also help retail investors. We strongly oppose cost benchmarks in RIS, which pose a risk of price regulation. Not only the costs but also qualitative aspects such as capital guarantees or sustainability features must be considered. Most of the RIS proposals run counter the objectives of SIU as they would make investment much more bureaucratic. The Commission needs to reflect how to proceed with RIS. Only through the demand-oriented allocation of loans and financing resources, as well as their subsequent transformation into investment products - including, if necessary, the separation of capital flows and the risks associated with lending - makes a participation of broad sections of the population in financing the European economy possible. Banks have to serve all financing forms, preventing an unbalanced shift toward capital market financing that would bypass the needs of European SMEs. Banks provide financing to businesses locally, in a demand-driven and sustainable manner. This proofs the share of bank financing in a European corporate landscape dominated by SMEs. In order not to jeopardise this financing, the enforceability of loan collateral in the event of insolvency must not be impaired by legislation at the European level, as this would have a negative impact on the credits supply. Insolvency-proof loan collateral is often a prerequisite for granting credit in the first place or the basis for lower interest rates on loans. Direct borrowing from capital markets would overwhelm the vast majority of companies.Only a mix of financing instruments enables a risk-appropriate, tiered product range that aligns with the individual savings and investment preferences of EU citizens. Since bank financing and financing via the capital market serve different target groups and needs, both must be equally promoted. Current tendencies at European level to further expand ESMA's powers in the context of SIU should be examined very carefully. Supervision in principle needs to remain the responsibility of NCAs. Good supervision must be close to national markets. The SIU does not require a broad harmonisation of insolvency law or of the ranking of claims, as this would do little to make the insolvency scenario much more predictable or have a positive effect on investment decisions. The real key factors are earnings opportunities, market access, taxation and bureaucracy. Furthermore, insolvency law is closely intertwined with national economic, labour and tax law. Therefore, a broad harmonisation would be complex and would require prior harmonisation of the respective areas of law. However, the modernisation of insolvency-related capital market regulations under the directives on financial collateral arrangements and on settlement finality in payment and securities settlement systems (together: rules for financial collateral and settlement) would be much more relevant for advancing the SIU.
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Meeting with Aurore Lalucq (Member of the European Parliament, Committee chair) and Bundesverband deutscher Banken e.V. and

19 Feb 2025 · Commission Work Programme and coming legislative proposals

Meeting with René Repasi (Member of the European Parliament) and Bundesverband deutscher Banken e.V. and

19 Feb 2025 · Austausch zu aktuellen Fragen der europäischen Finanzmarktpolitik

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

4 Feb 2025 · Banking Union/third pillar

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

16 Jan 2025 · Savings and Investments Union

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Bundesverband deutscher Banken e.V. and

16 Jan 2025 · Upcoming topics in sustainable finance

Meeting with Andrea Wechsler (Member of the European Parliament)

12 Dec 2024 · EU Policy

Meeting with Luděk Niedermayer (Member of the European Parliament, Rapporteur)

14 Nov 2024 · CMDI

Meeting with Daniel Caspary (Member of the European Parliament)

13 Nov 2024 · Austausch

Meeting with René Repasi (Member of the European Parliament) and Bundesverband deutscher Banken e.V. and

16 Oct 2024 · Working breakfast with German banking industry committee

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

16 Oct 2024 · developments in the financial services sector

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

14 Oct 2024 · Capital Markets Union / Retail Investment Strategy

Meeting with Moritz Körner (Member of the European Parliament)

19 Sept 2024 · Policy Developments in the Financial Services Sector

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

3 Sept 2024 · competitiveness of the European economy

Meeting with Matthias Ecke (Member of the European Parliament)

22 Aug 2024 · Kennenlernen / Finanzpolitik

Meeting with Matthias Ecke (Member of the European Parliament) and Gesamtverband der Deutschen Versicherungswirtschaft e.V. and

15 Mar 2024 · Kennenlernen / Finanzpolitik

Meeting with Martin Schirdewan (Member of the European Parliament, Shadow rapporteur)

25 Jan 2024 · Krisenmanagement im Bankensektor

Meeting with Michael Kauch (Member of the European Parliament)

25 Jan 2024 · General Exchange

Meeting with Joachim Schuster (Member of the European Parliament)

29 Nov 2023 · CMDI

Meeting with Esther De Lange (Member of the European Parliament)

12 Oct 2023 · CMDI - APA

Meeting with Joachim Schuster (Member of the European Parliament)

10 Oct 2023 · CMDI (on staff level)

Meeting with Stefan Berger (Member of the European Parliament, Rapporteur) and Die Deutsche Kreditwirtschaft

20 Sept 2023 · Digital Euro

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

11 Sept 2023 · Digital issues

German Savings Banks warn against commission bans and price regulation

7 Aug 2023
Topic — Proposed EU measures to increase retail investor participation in capital markets.
Message — The association opposes the proposed commission ban for non-advised sales and the value-for-money price test. They also demand a longer implementation period to handle the complex regulatory changes.123
Why — This would preserve their current commission-based revenue and avoid the cost of expensive technical upgrades.4
Impact — Individual investors might face higher fees or lose access to services in local banking branches.56
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Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

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

17 Jul 2023 · Kleinanlegerstrategie

Meeting with Deirdre O’Hea (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

6 Jul 2023 · Financial literacy

Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

14 Jun 2023

In addition to technical changes, the adjustments in the DGSD within the framework of the CMDI review primarily focus on preventive (including institutional protection) measures. Without merit, the EU-COM is thus shifting the focus of the DGSD review to market structures of networks of small and medium-sized regionally institutions. The newly formulated requirements for preventive measures are materially very high. In addition, the newly formulated process is very time-consuming. There are numerous requirements that are demanded: coordination processes with supervisory and resolution authorities, implementation of a least cost test (LCT), definition of a strict timetable in advance for the repayment of liquidity protection measures, limitation of the amount of funds that can be used, absence of failing or likely to fail. Preventive measures financed through the DGS financial means are thus no longer credibly functional; in numerous constellations, they cease to be feasible in the foreseeable future. Overall, the functionality of the institutional protection scheme is severely jeopardised. The DSGV cannot understand why proven preventive measures should be restricted. It is remarkable that this goal is to be achieved in particular through a multitude of small-scale bureaucratic regulations that slow down the entire process. In the event of a crisis, this will lead to a diffusion of responsibility. Thus, these proposals are neither in the interest of depositors and customers nor in the interest of financial market stability. Ultimately, the EU-COMs proposals massively weaken small and medium-sized regionally oriented institutions and violate the basic principle of proportionality. The DSGV therefore fully and strictly rejects the new requirements for the implementation of preventive measures. With regard to a mandatory LCT for preventive measures, there is particular criticism: a) Conflict with Article 113(7) CRR, which requires institutional protection schemes to safeguard the liquidity and solvency of the affiliated institutions. A mandatory LCT stands against this provision. It can be assumed that the requirements of Article 11a et seq. DGSD draft and, in particular, an LCT prevent the fulfilment of the requirement of Article 113(7) lit. a in conjunction with 113(6) lit. e CRR. The proposals of the EU-COM thus fundamentally impair the network systems of regional savings and retail banks. b) External benefits of the institutional protection - in particular the stability of existing credit facilities for regional small or medium-sized enterprises - as well as aspects of protecting the common brand within bank network structures are not taken into account. c) The calculation of the LCT on the basis of an EBA technical standard will foreseeably be very time-consuming, as a result of which preventive measures cannot be used or can only be used with a very long delay. d) The requirements do not consider the structure of financial networks in which the securities and capital market business is bundled in central institutions. Their volume of deposits is correspondingly low. Nevertheless, the central institutions and specialised institutions are necessary for the work of the deposit-based primary institutions. Finally, the CMDI review enforces a separation between deposit insurance and institutional protection through the newly set requirements for preventive measures. With this, the EU COM is preparing the implementation of the EDIS system, whereby credit institutions with institutional protection schemes will be forced to do double payments. Against this background, the proposals for a CMDI review are neither neutral regarding market structures nor do they take specificities of the national banking sectors into account. DSGV demands that all measures under the DGSD are explicitly not subject to state aid law. Art. 32c(1b) BRRD draft should be clarified: not to be considered as "Extraodinary Public Financial Support".
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

14 Jun 2023

BRRD Public Interest (Art. 32 (5) in conjunction with Art. 31(2) and Art. 2(1) No. 35 BRRD draft) The proposed approach of making resolution the standard for crisis management in the banking sector is foreseeably more bureaucratic and financially burdensome, especially in the case of small and medium-sized institutions. The EU-COM is thus aiming for a fundamental paradigm shift, as resolution was once conceived as a special response to "too big to fail". Now, a "public interest" in resolution should already exist in cases of strong regional - not just national or cross-border - significance of an institution. As a consequence, this reclassification creates considerable administrative and financial burden (reporting on resolution plans and compliance with MREL quotas with MREL capital) for institutions that previously went into liquidation (cf. Art. 32 (5) in conjunction with Art. 31(2) and Art. 2(1) No. 35 BRRD draft). These cumbersome requirements contradict the efforts of the European legislators in the CRR II to relieve small, non-complex institutions (SNCIs) of such obligations from a proportionality perspective. In the case of institutions that are only active on a regional level, negative shock effects on financial stability of the financial system cannot be assumed in principle in the event of distress. This is also underlined by the annual risk analysis carried out by the German Supervisory Authority (BaFin and Deutsche Bundesbank) for the small and medium-sized banks directly supervised by BaFin (Less Significant Institutions - LSIs). According to the assessment only 1.4% of LSIs consider the impact as high (all data as of December 31, 2022). If the preferred resolution strategy was no longer insolvency proceedings but resolution, it would be likely to be a major challenge for medium-sized and especially smaller institutions, which are often not capital market-oriented, to issue the eligible liabilities required to meet MREL. The set-up is further complicated by the minimum denomination for the sale of subordinated eligible liabilities to retail investors (Art. 44a BRRD) set by the last revision of the BRRD. Ultimately, this will also jeopardize the existence of small and medium-sized institutions with a traditional business model in the medium term, which can only meet the requirements through size. The DSGV therefore strongly rejects the significant extension of the scope of application of the BRRD draft. Order of precedence: Art. 108(1) BRRD is amended to the effect that all deposits have the same ranking in the event of insolvency, ranking above unsecured claims. The net costs of compensation cases therefore will likely increase. This is neither justified nor necessary. It can generate moral hazard and erode the confidence of depositors in the protection systems. Payments by the DGS in the event of resolution: Art. 109(2b) BRRD draft in conjunction with Art. 44(5) BRRD draft provides that payments made by the DGS in resolution should count towards the requirement of 8% of total liabilities and own funds (TLOF) for access to the resolution fund. The contribution of the DGS in the context of resolution is limited to the amount of the potential compensation case according to the least cost test as defined in Art. 11e DGSD draft. We oppose the outlined expansion of co-funding a resolution through deposit insurance funds. Particularly in conjunction with the planned extension of depositor protection to formerly unprotected deposits - which is contrary to the mandate - could have serious implications for funding requirements and lead to a financial erosion of the deposit guarantee schemes. Deletion of compulsory obligation of Art. 30a BRRD, which provides for an earlier start of resolution measures, is necessary: Such a rule would negatively affect the functioning of IPSs, as it would force them to initiate financial support measures for the affected institution even before it is "likely to fail.
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Response to Banking Union: Review of the bank crisis management and deposit insurance framework (SRMR review)

14 Jun 2023

SRMR The German Savings Banks Association remains critical of the view of the SRB and the EU Commission that the target level of the SRF is to be understood as dynamic and should therefore be at least 1% of covered deposits at all times. Unfortunately, the CMDI-Review does not contain any adjustments in this respect. The provision to defer the collection of contributions in cases where the amount of contributions is insignificant is primarily a procedural relief for the SRB and the resolution authorities and is appropriate in principle. However, clearer rules on when contributions are significant would be desirable. It is to be expected that institutions will continue to be required to report data on contributions to the SRF on an annual basis. As a result, the change will not have a material impact on the institutions, as the levying of contributions will only be postponed. The DSGV is critical of the adjustments to the contributions ceiling. Basically, the new regulation appears to be only a formal change compared to the current status quo. However, it is not possible to estimate the future target level. In this respect, the linking of ex-post contributions to the target level represents a significant deterioration.
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Response to Banking Union: clarifications to the daisy chain deductions

14 Jun 2023

Daisy Chain proposal DSGV appreciates the Commission´s proposal regarding the removal of the obligation for resolution authorities to set MREL for liquidation entities (if MREL being equated with the own funds requirements and thus is not been set above the level of exceeding the loss absorption amount). Furthermore, the removal of liquidation entities from the scope of the prior permission regime is highly appreciated.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Bundesverband der Deutschen Volksbanken und Raiffeisenbanken

7 Jun 2023 · CMDI review

Meeting with Esther De Lange (Member of the European Parliament)

5 Jun 2023 · CMDI review

Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

5 Jun 2023 · Taxonomy

Meeting with Joachim Schuster (Member of the European Parliament)

2 May 2023 · Banking Regulation

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

20 Apr 2023 · Retail Investment Strategy and CMDI Review

Meeting with Henrike Hahn (Member of the European Parliament)

12 Apr 2023 · Banking regulation

Meeting with Rasmus Andresen (Member of the European Parliament)

29 Mar 2023 · EU-Economic Governance Review

Meeting with Mairead McGuinness (Commissioner) and

28 Mar 2023 · Round-Table on Digital Euro (with EVP Dombrovskis and DG FISMA)

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

24 Mar 2023 · Introduction of the new CEO and exchange on SME Relief Package as well as the impact on SMEs of CSRD and CS3D.

Meeting with Esther De Lange (Member of the European Parliament)

23 Mar 2023 · CMDI review - APA

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Bundesverband deutscher Banken e.V. and

21 Mar 2023 · CMDI, Digital Euro

Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

9 Mar 2023 · Sustainability and its effects not only on the finance industry

Meeting with Joachim Schuster (Member of the European Parliament)

8 Mar 2023 · Banking regulation

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

10 Feb 2023 · crisis management and deposit insurance framework

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

10 Feb 2023 · Crisis management and deposit insurance framework

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness) and Bundesverband deutscher Banken e.V. and

18 Jan 2023 · Retail Investment Strategy

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Bundesverband deutscher Banken e.V. and

18 Jan 2023 · Retail investment strategy. ETFs.

Meeting with Mairead McGuinness (Commissioner) and

25 Oct 2022 · Financial Literacy

Meeting with Joachim Schuster (Member of the European Parliament)

11 Oct 2022 · Parliamentary Evening

Meeting with Nicola Beer (Member of the European Parliament, Shadow rapporteur)

6 Sept 2022 · Financial Market Regulation incl. MIFIR/D and CRR/CRD

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)

24 May 2022 · CRR (staff)

Meeting with Katarina Barley (Member of the European Parliament)

27 Apr 2022 · Exchange of views

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

25 Mar 2022 · European Payments Initiative

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Nicolo Brignoli (Cabinet of Commissioner Mairead Mcguinness) and

12 Jan 2022 · Retail Investments Strategy

Meeting with Bernhard Zimniok (Member of the European Parliament)

26 Oct 2021 · Parlamentarischer Abend des DSGV

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

6 Oct 2021 · Fit for 55, sustainable finance

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

30 Aug 2021

The Deutscher Sparkassen- und Giroverband (DSGV), for the savings banks finance group, the Bundesverband der Deutschen Volksbanken und Raiffeisenbanken (BVR), for the cooperative banks, the Bundesverband Banken Deutschlands (VÖB), for the public-sector banks, the and the Verband deutscher Pfandbriefbanken (vdp), for the Pfandbrief banks collectively represent the majority of the german banks. I. General Remarks on the proposed Implementing Act We expressly welcome the EU Commission's step to enact an Implementing Act to legally substitute CHF LIBOR. Although our members are currently reducing the exposure of contracts, which are having a reference to the tenors of the CHF LIBOR, it is hardly possible to amend them all in every business area. Against this background, the proposed Implementing Act is an important instrument to ensure legal certainty for all affected contracting parties and to avoid significant disruptions in the financial markets. We consider the legislative proposal to be very balanced. We also welcome the approach to include all contracts in the scope of the statutory replacement rate, if they do not have a(n appropriate) fallback provision until 31 December 2021. As there is no substitute for CHF-LIBOR based on a forward-looking method, we consider the switch to the SARON compound to be appropriate. The use of the last-reset approach appears appropriate especially for retail contracts. Since the customer knows his interest rate in advance. The fixing of the respective tenor-related spread in the Implementing Act is also a correct and important step. This creates a publicly accessible legal source. It creates transparency for all contracting parties and is an essential basis for a fair transition process that is as economically neutral as possible. II. Suggestions on the proposed Implementing Act It is already stated in Article 23b para. 3 of the Amending Regulation ((EU) 2021/168) that the statutory fallback rate only applies if no or no suitable fallback provision exists. Nevertheless, we consider a corresponding reference in the Implementing Act to be useful. This would significantly increase the legal understanding of the norm addressees and in practice. Furthermore, we would like to suggest that the (senseful) information requirement should not be linked to the written form. The information should also be able to be provided electronically to all affected clients in a timely manner, i.e. also to private clients and smaller counterparties. This also seems appropriate, especially against the background of advancing digitalisation and customer expectations with regard to a sustainable performance of the banking industry. Therefore, we propose to delete the passage "in writing". Our members will continue to work intensively on the active reduction of contracts with a reference to CHF LIBOR. As it will be discontinued on 31 December 2021, there is little time left for this. For the remaining contractual relationships, the Implementing Act will be decisive. In order to ensure a smooth changeover to the statutory fallback rate, appropriate preparations must be made. Therefore it would be very helpful if the Implementing Act would be finalised as soon as possible.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

7 Apr 2021 · Meeting w/ cab Dombrovskis, Basel III

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Bundesverband deutscher Banken e.V. and

7 Apr 2021 · Basel III

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

26 Mar 2021 · Basel III implementation

Meeting with Mairead McGuinness (Commissioner)

12 Feb 2021 · Banking Union

Meeting with Jérome Deslandes (Cabinet of Executive Vice-President Valdis Dombrovskis)

24 Feb 2020 · The European Deposit Insurance Scheme; Finalisation of Basel III

Meeting with Günther Oettinger (Commissioner)

26 Apr 2019 · MFF

Meeting with Kai Wynands (Cabinet of Vice-President Valdis Dombrovskis)

21 Mar 2019 · EMU

Meeting with Günther Oettinger (Commissioner)

20 Mar 2019 · Future of Europe

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

13 Dec 2018 · Banking package

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

13 Dec 2018 · banking union

Meeting with Markus Schulte (Cabinet of Vice-President Günther Oettinger)

18 Oct 2018 · MFF

Response to Multiannual Financial Framework-Draft legislative proposal on the InvestEU Programme and EFSI evaluation SWD

7 Aug 2018

Die Europäische Kommission hat am 6. Juni 2018 einen Verordnungsentwurf über das InvestEU-Programm für den Zeitraum 2021 bis 2027 veröffentlicht [KOM(2018) 439]. Bis zum 8. August 2018 können Betroffene und Beobachter Rückmeldungen dazu geben. Der Deutsche Sparkassen- und Giroverband (DSGV) schätzt diese Möglichkeit zur Kommentierung. Die Bündelung vieler bestehender EU-Finanzinstrumente in einem einzigen InvestEU-Fonds mit einheitlichen Regeln und Vertragstexten ist nach Ansicht des Deutschen Sparkassen- und Giroverbands gut geeignet, die nationale Umsetzung der Finanzinstrumente zu vereinfachen. Zugleich erleichtert die Übersichtlichkeit die Information und Beratung von KMU über verfügbare EU-Unterstützungen. Durch seine Ausgestaltung und Mittelausstattung ist der InvestEU-Fonds den Bedürfnissen der KMU grundsätzlich angemessen, bedarf aber in manchen Aspekten noch der sachgerechten Präzisierung. So werden Überschneidungen zwischen Förderfenstern nicht vollständig beseitigt und die ausstehende Definition konkreter Förderkriterien erfordert besondere Sorgfalt. Letztlich wird die tatsächliche nationale Umsetzung jeweils darüber entscheiden, wie passend Finanzierungsangebote für die Bedürfnisse von KMU sind und wie einfach die Information und Beratung von KMU über verfügbare Angebote ist.
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Meeting with Jyrki Katainen (Vice-President)

10 Jul 2018 · SME Financing in Germany: current situation and next MFF.

Meeting with Günther Oettinger (Commissioner)

10 Jul 2018 · MFF

Meeting with Valdis Dombrovskis (Vice-President) and

10 Jul 2018 · Banking Union: Banking Package and EDIS; non-performing loans (NPLs)

Response to Legislative proposal for an EU framework on crowd and peer to peer finance

9 May 2018

The National Association of German Cooperative Banks (BVR; transparency register number: 22330076571-75) and the German Savings Banks Association (DSGV; transparency register number: 62379064909-15) wish to comment as follows on the European Commission’s efforts to harmonize the market for crowdfunding service providers by introducing Europe-wide rules: The proposed regulation is aimed at enabling crowdfunding service providers to operate across borders within the European Union by creating uniform European rules and setting up a Europe-wide authorisation system. Under this system, crowdfunding service providers can choose whether to offer services only at national level in accordance with national rules or to obtain an EU passport that permits them to offer services nationally and across the EU on the basis of the EU regulation. The proposed regulation only applies to crowdfunding services entailing a financial return (crowdlending and crowdinvesting) and should make it easier for innovative companies, start-ups, and other unlisted companies to access finance. Uniform rules on the facilitation of lending-based and equity-based crowdfunding are also contained in the proposed regulation. We take a critical view of having a European approval framework alongside national rules, which would mean differences in the regulation of the services being provided. 1. From the perspective of private investors, the assessment of the default risk attaching to the investment varies depending on whether the crowdfunding arrangement is based on lending or on equity. 2. To ensure fair competition and to protect consumers, there must be certainty that comparable legal transactions are subject to consistent regulatory requirements. Under the regulation, the facilitation of the granting of loans will be subject to a single set of rules. It is therefore logical that there is also one set of EU-wide rules regulating the awarding of loans. Investors need to know for sure that lenders in the various member states are subject to the same requirements. Crowdlending constitutes a risky investment, while crowdinvesting is even a high-risk investment. As is currently the case in Germany, investor-specific income and investment limits need to be set in order to protect consumers. Investors in Germany are permitted to invest up to €1,000 without supplying any additional information. When investing more than €1,000 up to the maximum permitted amount of €10,000 per investor, the investor must submit a self-declaration stating that he or she has freely available assets of at least €100,000 or is investing no more than double the amount of his or her average monthly net income. The rules in the proposed regulation only apply to crowdfunding campaigns up to a maximum of €1.0 million per crowdfunding campaign in a twelve-month period. Counterparty risks arising when an issuer provides finance simultaneously for multiple crowdfunding campaigns have not been considered. The proposed regulation therefore needs to make clear that the limit applies to an issuer’s total issuance volume. It would also be good to clarify the level/basis on which the limit is calculated, e.g. on a project, group or legal entity basis. The BVR and DSGV welcome the rules in the proposed regulation regarding the information sheet containing comprehensive information on the crowdfunding project (including terms & conditions, details of the crowdfunding process, and explicit warnings that use the specified wording) and regarding the specific requirements on crowdfunding service providers and their management.
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

20 Mar 2018 · Banking Union

Meeting with Kai Wynands (Cabinet of Vice-President Valdis Dombrovskis)

30 Jan 2018 · EMU and Banking Union

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis), Kai Wynands (Cabinet of Vice-President Valdis Dombrovskis) and

5 Sept 2017 · Banking Union; ESA review; CRR/CRD; PSD2

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

13 Jul 2017 · CRR/CRD/Proportionality, PSD II

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

6 Jun 2017 · Speech on the European Banking Policy

Meeting with Günther Oettinger (Commissioner)

12 May 2017 · banking and financial services

Meeting with Valdis Dombrovskis (Vice-President) and

1 Mar 2017 · CRR/CRD; EDIS

Meeting with Günther Oettinger (Commissioner)

15 Nov 2016 · digitisation of finance sector

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

15 Nov 2016 · EFSI

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

13 Jul 2016 · Capital Markets Union, retail financing

Meeting with Jonathan Hill (Commissioner)

14 Apr 2016 · European Deposit Insurance Scheme

Meeting with Valdis Dombrovskis (Vice-President)

17 Feb 2016 · meeting with Mr Fahrenschon, Präsident des Deuschen Sparkassen- und Giroverbands

Meeting with Valdis Dombrovskis (Vice-President) and Bundesverband der Deutschen Volksbanken und Raiffeisenbanken

17 Feb 2016 · Hessische Reginalbankenkonferenz

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis), Tuure Taneli Lahti (Cabinet of Vice-President Valdis Dombrovskis)

10 Nov 2015 · EDIS

Meeting with Jonathan Hill (Commissioner)

10 Nov 2015 · European Deposit Insurance Scheme and Capital Markets Union

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

22 Oct 2015 · the Commissions' plans for a European deposit guarantee or reinsurance scheme, the capital markets union and the greenbook on retail financing

Meeting with Reinhard Felke (Cabinet of Commissioner Pierre Moscovici)

13 Oct 2015 · exchange on deepening EMU

Meeting with Valdis Dombrovskis (Vice-President) and

21 Sept 2015 · Deposit insurance/Banking Union

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

28 Aug 2015 · EU banking issues

Meeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)

15 Jul 2015 · Financial Services Policy

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

8 May 2015 · Investment initiative

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

26 Mar 2015 · European Semester

Meeting with Günther Oettinger (Commissioner)

6 Mar 2015 · Digital economy

Meeting with Valdis Dombrovskis (Vice-President) and

6 Mar 2015 · Banking regulatory issues – European semester

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

19 Feb 2015 · Capital Markets Union (CMU)