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European Association of Co-operative Banks

EACB

The European Association of Co-operative Banks represents 27 member institutions and defends the common interests of cooperative banks in Europe.

Lobbying Activity

Meeting with Pawel Wisniewski (Cabinet of Commissioner Christophe Hansen)

18 Dec 2025 · Financing EU agriculture

Meeting with Yvo Volman (Director Communications Networks, Content and Technology)

12 Dec 2025 · Data Union Strategy, data aspects of the Digital Omnibus

Co-operative banks urge EU to simplify green finance rules

5 Dec 2025
Topic — A consultation reviewing and simplifying technical screening criteria for the EU Taxonomy.
Message — The EACB requests simplified reporting templates to reduce administrative burdens for financial companies. They specifically ask to remove documentary requirements for private renovations and relax inaccessible data criteria.123
Why — This would reduce administrative costs and enable more practical lending for green transitions.4
Impact — Environmental groups lose oversight as banks seek to remove circular economy and pollution criteria.5
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Meeting with Malgorzata Nikowska (Head of Unit Communications Networks, Content and Technology)

12 Nov 2025 · Initial Exchange and Identification of Common Themes with EACB

Meeting with Dan Dionisie (Head of Unit Justice and Consumers)

20 Oct 2025 · Exchange on ECB guide, EBA guidelines and SRD

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

14 Oct 2025 · Nature Credits

Meeting with Eric Ducoulombier (Acting Director Financial Stability, Financial Services and Capital Markets Union) and European Banking Federation and

9 Oct 2025 · Implementation of two obligations for payment service providers under the Instant Payments Regulation

Meeting with Eric Ducoulombier (Acting Director Financial Stability, Financial Services and Capital Markets Union)

9 Sept 2025 · Exchange of views on the proposal for a Regulation on a framework for Financial Data Access (FIDA), digital euro, retail investment strategy (RIS) and the omnibus proposal.

Co-operative banks urge EU to simplify complex data rules

18 Jul 2025
Topic — The European Commission is seeking feedback on a strategy to streamline data-sharing rules.
Message — The EACB calls for streamlining data rules to ensure legal coherence. They urge officials to reconsider financial data access rules to avoid creating isolated silos.12
Why — Streamlining would reduce high compliance costs and eliminate redundant regulatory requirements.34
Impact — European companies lose the ability to innovate due to overly complex and restrictive laws.5
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Co-operative banks urge EU to upgrade securitisation liquidity status

15 Jul 2025
Topic — Review of liquidity coverage rules for bank and insurance securitisation exposures.
Message — The EACB wants high-rated securitisations promoted to better liquidity categories. They also favor removing maturity barriers and lowering haircuts to encourage investment.12
Why — Better liquidity classifications would lower costs and boost bank market participation.3
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Meeting with Pawel Wisniewski (Cabinet of Commissioner Christophe Hansen)

14 Jul 2025 · Exchange of views on the role of cooperative banks in agricultural financing

Meeting with Markus Ferber (Member of the European Parliament)

11 Jun 2025 · Digital euro

Meeting with Maria Luís Albuquerque (Commissioner) and

11 Jun 2025 · Exchange on regulatory files

Co-operative banks urge legal clarity in EU AI Strategy

4 Jun 2025
Topic — The initiative aims to boost industrial AI uses and improve public services.
Message — The association calls for precise definitions of AI systems to protect rule-based tools from regulation. They also demand faster publication of regulatory gap analyses for the banking sector.12
Why — Clearer rules would reduce compliance costs and help banks innovate more quickly.3
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Meeting with Marco Falcone (Member of the European Parliament)

27 May 2025 · Politiche abitative

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

14 May 2025 · Financial data access framework (FIDA)

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and Insurance Europe and

22 Apr 2025 · FIDA

Co-operative banks dismiss EU taxonomy simplification as window-dressing

26 Mar 2025
Topic — Initiative to simplify EU taxonomy reporting requirements and reduce administrative costs for companies.
Message — The group requests excluding optional-reporting firms from Green Asset Ratio calculations to maintain accurate data. They also propose removing trading book indicators and simplifying nuclear and fossil fuel reporting templates.123
Why — These measures would reduce administrative costs by eliminating the need for complex manual data collection from clients.4
Impact — Small businesses could face financing delays as banks struggle to gather necessary environmental data to meet standards.5
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EACB Urges Lower Capital Charges to Boost SME Lending

26 Mar 2025
Topic — Review of the EU's securitisation framework covering transparency and prudential requirements for banks.
Message — The association calls for a supportive regulatory environment to help small businesses access capital through securitisation. They suggest simplifying due diligence processes and lowering high capital charges that make these transactions unattractive. Additionally, they advocate for better treatment of these assets in bank liquidity calculations.123
Why — These reforms would lower operational costs and free up bank capital for lending.4
Impact — Financial regulators lose detailed oversight as reporting and data maintenance requirements are reduced.5
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Meeting with Michalis Hadjipantela (Member of the European Parliament)

21 Mar 2025 · Introductory Meeting

EACB urges permanent lower charges for bank repo transactions

6 Mar 2025
Topic — Proposed changes to the net stable funding ratio for securities financing transactions.
Message — The group wants current temporary rules for secured funding made permanent to avoid a massive rise in costs. They stress that banks need regulatory clarity well before the June 2025 deadline.12
Why — Maintaining these rules reduces costs and protects banks against non-EU competitors.34
Impact — Sovereign debt markets lose liquidity because trading government bonds becomes too expensive.56
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Response to Savings and Investments Union

3 Mar 2025

The EACB welcomes the development of a Savings and Investments Union (SIU), encompassing both the Banking Union and the Capital Markets Union. For our banks members strengthening EU capital markets, while maintaining a diversified financial and banking system and remaining globally competitive, is key. Cooperative banks, with their strong local presence, are uniquely positioned to contribute to the SIUs objectives by promoting retail investor participation, mobilizing savings, and ensuring financing for SMEs and infrastructure projects. To meet the SIU goals, policymakers should: 1. Align Capital Markets Initiatives with Bank Financing & Banking Union incentives: An efficient financial system requires interplay between bank lending and financial markets. Banks, especially cooperatives, have a key role in financing SMEs , households, and fostering retail investors participation. Improving the circulation of capital and liquidity in the Banking Union and rendering the single market more efficient, while reflecting the needs of diverse banking models, will benefit both institutions and borrowers. 2. Focus on Investors, Enhance Existing Instruments, Promote financial education and collaborate with industry stakeholders: Encouraging retail participation in capital markets is a cornerstone of the SIU. This requires simplifying access to financial markets, adapting existing tools, such as ELTIF, for retail investors, supporting themespecially first-time and less affluent saversand promoting financial education. Initiatives aiming at reducing risk aversion, such as enhancing financial literacy and/or introducing a preferential tax treatment on certain investments, will be crucial. Open dialogue and collaboration between policymakers and industry representatives will be key to creative effective policy in the SIU remit. 3. Reduce Regulatory Complexity, Ensure Consistency and Minimize Revisions: Legislative consistency is crucial for market stability. Repeated legislative revisions impose significant costs and bureaucracy on banks and taxpayers. The SIU should focus on cutting red tape, simplification and minimize legislative reviews. For example the separate transaction reporting regimes of EMIR, MIFIR, SFTR and MMSR could be simplified by deleting investment firms MIFIR reporting requirements for derivatives and integrating, if needed, extra requirements in investment firms derivatives reporting under EMIR. 4. Enhance Securitisation and SME Financing: A more supportive regulatory environment is needed to develop securitisation markets. Additionally, the European Secured Notes (ESNs) initiative should be explored as an additional tool for SME financing. 5. Strengthen Equity Financing and Reduce Tax Barriers: Targeted adjustments to Basel IV/CRR3 can help foster greater equity financing and access to capital markets. Reducing tax-related barriers and harmonizing fiscal incentives across the EU will be key to unlock investments. 6. Enhance Long-Term Investment Tools: The European Long-Term Investment Fund (ELTIF) should be optimized to channel private capital into projects financing the EU transformation. A state-backed ELTIF with minimum allocations in EU projects could be a valuable tool. Promoting the labeling of existing EU products and a coordinated approach to national tax incentives could further enhance the attractiveness of long-term investments. 7. Leverage EU Guarantees for Risk Reduction: Public guarantees from institutions such as the European Investment Bank (EIB) could reduce financial risk and support bank lending for strategic EU projects. Furthermore, extending the use of guarantees to instruments such as green bonds could increase institutional investors interest in said instruments, particularly in less developed markets. Such action would both contribute to the development of our capital markets and increase the security of savings. Refer to our attachment for more details.
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Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

20 Feb 2025 · Meeting with the European Association of Co-operative Banks on regulatory developments

Meeting with Markus Ferber (Member of the European Parliament)

19 Feb 2025 · Competitiveness and simplification agenda

Meeting with Bruno Gonçalves (Member of the European Parliament)

19 Feb 2025 · ECON policies

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

17 Feb 2025 · To promote the SIU, the EACB proposes simplified reporting requirements, and a simple, low-risk investment product. They propose no entrance fees to encourage more people to start investing and support a review of the securitisation framework.

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

11 Feb 2025 · SF and Sustainability Omnibus

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

13 Nov 2024 · outlook for 2025 and prospective priorities

Co-operative banks urge simplified voluntary rules for renovation lending

5 Nov 2024
Topic — The Commission is establishing a voluntary portfolio framework for energy renovation lending.
Message — The EACB supports a voluntary framework that simplifies regulatory hurdles and relies on existing reporting. They propose a European guarantee fund and 'refill loans' to provide unbureaucratic credit decisions for existing customers.123
Why — This would reduce credit risk and lower capital costs for cooperative banks.45
Impact — Social and environmental safeguards are weakened if 'do no significant harm' requirements are removed.6
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Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

18 Oct 2024 · Draghi and Letta reports

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

11 Oct 2024 · Retail Investment Strategy

Meeting with Nicolo Brignoli (Cabinet of Executive Vice-President Valdis Dombrovskis)

8 Jul 2024 · sustainable finance, digital finance, co-operative banks

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

25 Apr 2024 · CMU, Competitiveness

Meeting with Esther De Lange (Cabinet of Commissioner Wopke Hoekstra)

20 Mar 2024 · An open discussion on the new business models for farmers on a transition to a more sustainable agriculture and the role cooperative banks can play in the financing needs of the farming sector

Response to Business in Europe: Framework for Income Taxation (BEFIT)

23 Jan 2024

The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the European Commissions legislative proposal for a Council Directive on Business in Europe: Framework for income Taxation (BEFIT). The EACB would welcome an actual decrease of compliance burden. Contrary to the objective of simplifying the compliance landscape, the latest proposal will subject taxpayers to a comprehensive set of corporate tax rules including BEFIT accounting, Pillar 2 accounting, accounting for local adjustments and transfer pricing. Not only there will be even more tax rules to be implemented and follow, but also the compliance costs will be added to the costs of implementing Pillar 2. This would lead to increased obligations and result in a much more complex framework, which is not appropriate to us. While the EACB welcomes the introduction of a One-Stop-Shop, attention should be paid to the fact that as per article 65 of the current proposal audits will continue to be conducted at the national level. Moreover, the proposal specifies that BEFIT Teams would be providing a degree of early certainty on specific topics. The EACB would like to point out that audits conducted at the level of a Member State seem to counteract the intended benefits of a One-Stop-Shop. In this context, the concept of the degree of early certainty needs to be clarified. While we understand the Member States interest in the early-stage involvement as demonstrated in the proposed BEFIT Teams set up with representatives of each relevant tax administration from the Member States, however, we are concerned that such arrangement may potentially lead to lengthy discussions or even permanent disagreement. We would welcome further clarification on how taxpayers can be assured that certainty is not only possible but will indeed be achieved. Additionally, we wish to emphasize the points outlined below. 1. With regards to the proposed article 60 (1) in section 3 When a member of a BEFIT team consults other members, it shall receive a response within a reasonable time, additional and more detailed information regarding the term reasonable time would be appreciate. 2. Further clarifications are also necessary regarding a draft article 61 (2): The BEFIT team shall endeavour to achieve consensus on the content of the BEFIT information return, within four months of the date when all information required under Article 57 was reported. In particular, while endeavour seems to suggest a best effort obligation, clarity should be provided concerning the situations when no consensus can be reached. In the context of regulated entities, specifically those in the banking and insurance sectors, local booking of deferred tax assets (DTA) for losses may remain relevant in relation to compliance with local capital requirements. Therefore, we would like to stress the importance of aligning tax considerations with local capital adequacy regulations for entities operating in the banking and insurance industries. According to the proposed article 57, the BEFIT information return must be submitted within four months after the end of the fiscal year, whilst the individual tax return should be filed within three months after receiving notification from the filing authority. In this respect, the EACB would like to stress that the proposed filing dates pose challenges, considering that taxpayers must navigate the simultaneous requirements of Pillar 2 and local tax return calculations. Finally, we underscore the importance of a sufficient preparation period ahead of the BEFIT adoption.
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Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

22 Jan 2024 · AGRI Dialogue

Meeting with Stefan Berger (Member of the European Parliament, Rapporteur)

9 Jan 2024 · Digital

Response to Payment services – revision of EU rules (new Regulation)

31 Oct 2023

The European Association of Co-operative Banks (EACB) welcomes the opportunity to provide feedback on the European Commission's proposals for a Payment Services Regulation (PSR) and Payment Services Directive (PSD3). The EACB actively contributed to the PSD2 review process with our input reflecting the views of cooperative banks across the EU. We believe that PSD2 has brought benefits for payment users by making payments safer and more secure through the implementation of strong customer authentication, although new kinds of fraud have developed, and the methods used by fraudsters changed after the implementation of PSD2. Besides that, PSD2 has created a market for third-party providers (TPPs), created more trust with consumers in sharing customer data, and has proliferated APIs. The EACB considers that retail payments sector is well regulated by a broad range of EU legislative acts and further regulatory intervention is not warranted. The proposal for a draft PSR contains a number of positive provisions with regard to the open banking, e.g. access to customers payment accounts by TPPs would only be possible via dedicated interfaces (API); no new EU API standard would be imposed on market actors; orientation of APIs towards international industry standards, such as the Berlin Group interface; small banks that have very limited or no data traffic through API would be allowed to ask national competent authorities an authorisation not to offer APIs and any other interface. We also welcome the proposal to enable merchants to offer cash withdrawal service up to EUR 50 (even in the absence of any purchase of goods or services) without the need to obtain a payment institution license. Cash in shop would be an alternative option for users to access cash and complement current possibilities. Notwithstanding the above positive developments, we have strong concerns regarding a sizeable negative effect and unintended consequences that other proposals under the draft PSR could have for the functioning of the EU payments market. Contrary to the Commission's announcement that its regulatory proposals represent an evolution not a revolution of the EU payments framework, our initial assessment is that there are surprisingly many detailed changes compared to the previous regulatory texts. An extensive revision of PSD2 will leads to high complexity and involves potentially unintended interactions. Second, one of the key lessons learned from PSD2 was that open banking cannot work properly without a sustainable business model, i.e. a fair distribution of value and risk among market actors is needed. However, the Commissions proposal would maintain the existing status quo with a free of charge access to bank customers payment account data by TPPs. Third, by shifting liability for authorized fraudulent transactions to payment services providers PSR would undermine the current balance between liability of payment service users and PSPs in case of fraud and would have negative consequences for market actors without tackling the source of the problem (e.g. social engineering fraud). Please read the attached position paper to review our detailed comments and suggestions for changes to the draft PSR and PSD3.
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Co-operative banks demand voluntary schemes and limited data scope

6 Oct 2023
Topic — The European Commission proposal establishing a framework for sharing financial customer data.
Message — The association requests that data sharing schemes be voluntary rather than mandatory and implemented over a longer timeline. They advocate for a gradual approach that excludes sensitive derived data and limits requirements for continuous real-time access.123
Why — Narrower data requirements would protect proprietary trade secrets and lower technical infrastructure costs.45
Impact — Large technology companies would be blocked from accessing banking data to protect traditional retail models.6
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Meeting with Eero Heinäluoma (Member of the European Parliament, Rapporteur)

19 Sept 2023 · Anti-money laundering

Co-operative banks urge clearer liability in EU tax relief plan

18 Sept 2023
Topic — The initiative introduces a common EU-wide system for withholding tax relief.
Message — The association requests clear liability standards for banks and the ability to charge service fees. They believe banks should only report information they already hold.12
Why — Clearer rules and restricted reporting would reduce operational burdens and legal uncertainty.3
Impact — Investors may face higher costs if banks charge fees for processing tax refunds.4
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Response to Establishing the digital euro

8 Sept 2023

The European Association of Co-operative Banks (EACB) welcomes the opportunity to provide feedback on the European Commission's proposal for a Regulation on the establishment of the digital euro. Please find the EACB position attached.
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Co-operative banks demand recognition of unique governance in ESG ratings

1 Sept 2023
Topic — EU proposal to regulate environmental, social, and governance rating providers and methodologies.
Message — The association calls for rating methodologies to explicitly account for the democratic and long-term nature of co-operative banking. They also request mandatory transparency regarding rating data and the ability for banks to correct errors before publication.12
Why — This would improve their ratings by ensuring their stable business model is recognized as a positive factor.3
Impact — Foreign rating providers would lose their current regulatory advantage over European-based competitors.4
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Response to Banking Union: clarifications to the daisy chain deductions

2 Aug 2023

The comments here provided only focus on issues of relevance for the clarifications to the "Daisy chain" deductions and do not touch upon other aspects of the CMDI package. Looking at Art. 45f on sub-consolidated internal MREL requirement, we would highlight that the impact/ interest of the proposed amendments to rules on daisy chains is asymmetrical depending on the institutions and group structures. Regarding the possibility of having an internal MREL requirement at the sub-consolidated level, members believe it should be up to the entities (and no longer in the discretion of the authorities) to request such an arrangement. This would enable institutions to make the request when it is suitable given the capital allocation structure and strategy of the group, instead of having it imposed on them without due consideration of these elements. The removal of liquidation entities for which the authority has not set a MREL from the scope of the prior permission (Art. 45c) seems appropriate, as it would improve overall proportionality in the framework.
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Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

Cooperative banks urge mandatory corporate data to ensure compliance

7 Jul 2023
Topic — New European standards specifying how companies must report sustainability and ESG information.
Message — The EACB requests that specific data points remain mandatory for all companies to ensure banks receive information needed for their own regulatory reporting. They also call for better alignment with international standards to prevent redundant paperwork for financial institutions.12
Why — This would guarantee that banks receive reliable data from clients, reducing their regulatory risk.3
Impact — Corporate clients lose the flexibility to omit reporting on topics they consider irrelevant.4
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Meeting with Paul Tang (Member of the European Parliament, Rapporteur)

24 May 2023 · Staff Level: 6th Anti-money Laundering Directive

Co-operative banks urge phased-in timeline for EU taxonomy reporting

3 May 2023
Topic — The consultation establishes technical screening criteria for identifying environmentally sustainable economic activities.
Message — The association supports the view that reporting should be phased-in. They suggest that the requirement for financial entities to report should be postponed.12
Why — This ensures that relevant data will be available to properly fill out reporting templates.34
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Meeting with Valdis Dombrovskis (Executive Vice-President)

27 Apr 2023 · digital Euro

Response to VAT in the Digital Age

3 Apr 2023

We appreciate that in the current proposal for a Directive, Article 272(1)(c) of VAT Directive 2006/112/EC exempting taxable persons carrying out only supplies of goods or of services remains unchanged. However, for the financial sector the proposal could be optimised by amending Article 272(1)(c) in such a manner that: - it is not an option for Member States but rather a mandatory exclusion; - it does also apply to tax payers that perform both taxable and exempt supplies, naturally limiting the exclusion to those VAT exempt supplies only; - the application can be based on the knowledge of the tax payer about the scope of the VAT exemption in the Member State of its own establishment, and thus not on the basis of a Member State in which the client / recipient of the supply is established. This is because a tax payer cannot know the precise scope of VAT exemptions, which in reality is not fully harmonised across the EU. Further to that, there is a number of issues that the EACB encourages the European Commission to consider in its future deliberations on the proposal for a Directive as regards VAT rules for the digital age. First of all, we would like to reiterate our concern expressed by the EACB during the 2022 public consultation stage with regards to the amount of data that is required. We firmly believe that the reporting obligations have to be reduced to data that is needed to fight tax fraud. Data security has to be ensured and the provisions must clearly state for which purpose the vast volume of data received by the Member States is collected, including how the data can be examined by tax authorities. When it comes to the proposed time limit for the issuance of invoices of two working days after the chargeable event takes place, EACB members are of the opinion that this deadline is too short and unlikely to be feasible for companies, especially for small entities. Further to that, in our understanding of Article 262 of the current proposal for a Directive the supplier as well as the recipient of a service have to submit the invoice data. However, it is unclear to us whether the recipient has to audit the invoice data that he has received. Besides the recipients verification obligations of an electronic invoice, clear instructions should be provided for cases when a mistake has been identified, for example a wrong number of the supplied goods. Moreover, as regards the content of invoices as stipulated in Article 226, clarity should be provided on what data needs to be reported in cases when no payment has been stipulated, for example in case of an exchange of services. Concerning the omission of the possibility to submit a summary invoice for several separate supplies of goods or services instead of many separate invoices, we urge the Commission to reevaluate the deletion of Article 223 of Directive 2014/55/EU with the view to increase the efficiency. Finally, clarification needs to be inserted as regards the situations when invoices are drawn up by the recipient of goods or services instead of a taxable person, if there is a prior agreement between the two parties. Please see attached a full EACB position paper.
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European Co-operative Banks Seek Continued Third-Country Benchmark Access

28 Mar 2023
Topic — Review of EU rules for financial benchmarks and non-EU benchmark usage.
Message — The organization calls for a temporary suspension of current rules until 2026 and a shift to regulating only systemically important benchmarks. They also recommend delaying any new EU environmental labels for benchmarks until other sustainability rules are finalized.123
Why — This would prevent disruption to their global investment funds and reduce compliance barriers for foreign administrators.45
Impact — End-clients and investors lose out if funds must abruptly stop tracking established global indexes.6
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Meeting with Mairead McGuinness (Commissioner) and

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

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

15 Mar 2023 · EU economy and Basel reforms

Co-operative banks urge limits on AI liability evidence disclosure

28 Nov 2022
Topic — The European Commission is proposing new civil liability rules specifically for artificial intelligence systems.
Message — The EACB requests limiting evidence disclosure to protect trade secrets and sensitive banking data. They also oppose mandatory insurance and believe the directive should exclude non-high-risk AI systems.12
Why — Limiting disclosure prevents competitors or criminals from accessing sensitive internal datasets and security protocols.3
Impact — Damage victims may struggle to prove liability if access to technical data is restricted.4
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2022 · Corporate Sustainability Due Diligence

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

12 Sept 2022 · CMDI

Co-operative banks seek broader exemptions from debt-equity tax rules

29 Jul 2022
Topic — An EU proposal reducing tax advantages for corporate debt versus equity financing.
Message — The organization requests that entire consolidated tax groups led by a bank be exempted from the rules. They also advocate for including leasing companies in the financial undertaking exemption. Finally, they fear limiting interest deductions could make bank loans less attractive to clients.123
Why — This would protect the competitiveness of bank lending and simplify group tax compliance.45
Impact — Corporate borrowers face higher net costs due to restricted interest tax deductions.6
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Meeting with Mairead McGuinness (Commissioner) and

19 Jul 2022 · Banking Union, Banking Package and Digital Euro.

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

8 Jul 2022 · Data Act

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

7 Jul 2022 · Banking regulation

Response to Open finance framework

4 Jul 2022

We welcome the EC’s data strategy and its commitment to creating a single market for data that will constitute a potential source of growth and innovation. Recognizing the leading role of the financial sector in the overall digital transformation of the economy, the EC’s ambition to promote data-driven innovation through an EU financial data space is also understood. The EC rightly lists a non-exhaustive number of already existing cross-sectoral rules on data access (e.g., the GDPR, e-Privacy Directive, DGA, DMA and the Data Act). In addition, the PSD2 represents the most relevant piece of sectoral legislation with regard to access to (payment account) data. When it comes to the different policy options proposed by the EC, we would formulate the following considerations: 1. The EC should be cautious in already suggesting policy options regarding the setting up of an open finance framework while it is undergoing the PSD2 review. Co-operative banks consider that the experience with PSD2 holds valuable lessons such as: a) For a data sharing economy to be successful, it needs the right incentives. It needs to allow all parties in the chain to derive benefits and build a business model so as to create incentives to foster innovation. There are limits to what a legislative approach can achieve. The realization of the PSD objective to open bank infrastructures and data to non-banks required a multilevel legislation. Level 1 to set high level objectives, level 2 to define RTSs. Practice has shown however that those two levels were not enough. Many additional discussions between stakeholders and several additional guidelines and opinions were necessary to guide the market. Additionally, a multistakeholder initiative under the ERPB is presently working to further develop services beyond PSD2. b) Measure benefits against costs. All the efforts put in place by market participants (IT, staff, expert group work, adjustment of T&Cs) notably to facilitate AIS services have not generated much demand. Indeed, API usage is rather low. Even EACB members that act as AISP do not see many clients using the AIS services. This despite all the investments put in. Together with other payment compliance work this has put pressure on banks’ capacity to develop new services and new solutions for clients without delivering the envisaged benefits. 2. The risks versus the benefits of data access should be considered. We strongly believe that a careful risk assessment should be done to estimate whether the benefits are greater than the risks for the various actors in the ecosystem. Just to name a few, data protection, both in terms of privacy and ‘informed consent’, fraud and security aspects should be factored in both from customers’ and companies’ perspectives. An open saving/insurance/investment framework shouldn’t lead to consumers losing control over data, and the banking and financial sector facing unintentional administration, development and legal uncertainty. The latter will cause a loss of economic activity from data holders’ data processing that so far has not been proved to be compensated by an equivalent or higher level of new economic activity derived from sharing. 3. Data sharing from other parties towards the financial sector should also be considered. The assumption seems to be that open finance should be about the financial sector opening up its data to other parties. However, we believe that data usage, access and sharing should be considered in a broad context, with a focus on cross-sectoral data sharing between all sectors of society. There are several uses cases in which the financial sector would benefit from data shared by for example public bodies. Should the EC decide for one of the policy actions, we recommend factoring in the EU principles of a market economy with freedom of contract to allow for sustainable business models to be developed and a level playing field for all economic actors that is fair for all participants.
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Meeting with Karolin Braunsberger-Reinhold (Member of the European Parliament, Shadow rapporteur)

30 May 2022 · AMLR

European Co-operative Banks Urge Fairer Data Sharing Framework

12 May 2022
Topic — The initiative aims to facilitate data sharing while reviewing database legal protection rules.
Message — The association insists data sharing remains voluntary and contractual while ensuring a level playing field. They call for clearer definitions of connected products and more time to switch cloud services.123
Why — This would ensure they receive financial compensation and protect their competitive business models.45
Impact — Public authorities would face more hurdles and delays when requesting data for the common good.6
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Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur) and Banking Payments Federation Ireland

12 May 2022 · CRR (staff)

Response to Minimum level of taxation for large multinational groups

6 Apr 2022

With regard to the practical impact, the EACB asks the Commission to clarify: • treatment of deferred taxes, given that - for purpose of determining turnover, taxes and the tax base - covered taxes include not only local taxes on income and earnings, but also complex corrections for deferred taxes (Articles 19-21); • considering that the effective tax rates (ETR) are derived based on the country-by-country reports required in the Council Directive (EU) 2016/881, we would appreciate a specific mention of whether the Commission considers approving that the complex calculations using the formula of ETR specified in the proposed Directive are not made for jurisdictions in which a MNE group shows an ETR of 15% or more in its country-by-country report; • as for equity participations in a foreign currency, there may be a mismatch in the Pillar 2 treatment of the (un)realised foreign exchange gains or losses on the participation and the (un)realised result on a hedging instrument that covers such a participation. The EACB would welcome a confirmation whether the opposing effects would both be treated in the same way (i.e., eliminated for Pillar 2 purposes); • given that GloBE includes highly complex rules and regulations for transparent/hybrid companies, permanent establishments, joint ventures, M&A transactions that need to be reflected in the company's IT landscape, it should be taken into account that the transposition of Pillar 2 would entail the establishment of new "GloBE company codes"; • which standard of calculation should be used, i.e., whether the MSs would be allowed to prescribe the valuation of assets according to national rules; • whether a “whitelist” could include countries that already have in place sufficient taxation and for which an application of the minimum tax could thus be omitted; • as regards joint ventures, it should be specified whether the “de minimis rule” could be applicable once the joint venture and its joint venture affiliates would meet the requirements for this rule. Regarding the text of the proposal: • as for the Article 11, we doubt that the concepts of an Ultimate Parent Entity established in the EU (UPE) and an Intermediate Parent Entity (IPE) are clearly established. From the recitals it can be read that the UTPR top-up tax will only be levied if an adequate IIR top-up tax is absent at either the level of an UPE or an IPE. In this respect Article 11 refers to a top-up tax levied from an UPE, but not of that of an IPE. • we would encourage to consider an alignment of “participation exemption” under Article 15 of the proposed Directive on Pillar 2 with the notion of “parent company” as stated in Article 3 point 1 (a) of the EU Parent-Subsidiary Directive (Council Directive 2003/123/EC). Application of the same definition to the “participation exemption” would result in: “’excluded dividend’ means a dividend or another distribution received or accrued in respect of an ownership interest, except a dividend or another distribution received or accrued in respect of: i) an ownership interest in an entity for which the constituent entity is not a ‘parent company’ in terms of Council Directive 2011/96/EU in the Member State of its establishment.” • as regards joint operations, there is a room for clarity on whether the special rules for joint ventures indeed do not apply to joint operations in which at least 50% is held, now that IFRS does not prescribe the equity method for these entities; • it needs to be clarified whether the reduction of the top-up tax due by the joint venture group will also apply for the allocable share of a member of the joint venture that is not in scope of the Pillar 2 rules (e.g. due to its size); • it would be appropriate to specify if Article 13 is applicable for situations in which the UPE is established in an EU country, and whether any remaining amount of top-up tax as mentioned in article 34 sub 4 cannot be added to the total UTPR top-up tax.
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Meeting with Pedro Marques (Member of the European Parliament, Shadow rapporteur)

8 Mar 2022 · AMLA

Response to Alignment of EU rules on capital requirements to international standards (review processes)

23 Dec 2021

The EACB particularly notes that the amendments to the CRD are not limited to complementing the Basel reforms but are rather sweeping, extending in many respects the powers of supervisors, from fit & proper assessments to new sanctioning tools to acquisition transactions. We find the extension inadequate in some cases. With regard to ESG risks, supervisory discretion should not be left unchecked. The wording of certain provisions leaves a very wide room for interpretation, especially when looking at the stated possibility of risks of misalignment “with the relevant Union policy objectives or broader transition trends towards a sustainable economy” (Art. 76(2), 87a, 104(1)(m)). Broad consideration of policy objectives and transition trends for supervisory action would leave institutions unable to properly define how to chart their strategy and milestones and to which supervisory expectations to adhere, supervisors would be left without clear guidance too. The ESG mandate in the SREP is already targeted to address ESG risks and ensure that banks actively and substantially contribute to the transition. The proposals in the area of governance, fit & proper requirements, reveal far reaching as well. We do not agree with the EC’s plans to harmonise the timing of the fit & proper assessments. It should remain in the discretion of Member States. We reject proposals for an assessment of the key function holders by the authorities. Any reform tackling an evaluation of directors should aim in the first place at ensuring timely processes and respect for constitutional and labour rights of candidates, i.e. right to appeal and termination conditions. In addition, we are concerned that the requirements in Article 88(3) to map and keep individual statements of duties of the members of the boards are contrary to the collegial liability of the board which is the legal standard in some MS. The description of the positions (3(8a), 3(9)) should be elaborated in view of the existing differences in the corporate laws and clearly attachable to concrete persons – this is crucial for the sake of legal clarity and correct implementation of the requirements, avoiding a too broad scope. Any new requirement should be adequately considered in light of the principle of proportionality. We believe that the current proposal is not sufficiently explicit on this (e.g. Art. 21, 91a to d) and should give more recognition to existing arrangements in groups like cooperative ones (e.g. banks affiliated to a central body). We are critical about expanding EBA mandate in the area. The current practice of supervisory authorities regarding capital add-ons due to the SREP outcome impedes institutions to reconstruct which of the imposed additional own funds requirements are allocated to the respective risks not covered under Pillar 1. Supervisory authorities impose an overall SREP-add-on without allocating the additional own funds to the concrete additional risks. This lack of transparency makes it elusive for the institutions to understand how supplementary own funds relate to specific risks and make it impossible to raise legal actions against a decision by supervisory authorities. We believe that supervisory authorities should have to clarify in their SREP decisions that (possible) capital add-ons are assigned to specific risk exposures with concrete amounts. Such specification would significantly improve transparency, clarity and credibility of the SREP. This would also allow to dispel existing doubts that certain risks, which are covered under macroprudential buffers, are double counted in the microprudential requirements. To keep an overall balance, discussions should progress in parallel on the entire proposal. Even if some CRR/BRRD items require technical changes, they should not be treated under fast-track procedure, or the urgent procedure should encompass all technical changes/corrections necessary in the current framework.
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Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

23 Dec 2021

The fundamental problem of the implementation of the latest Basel standards resides in choices made at Basel level which make an adequate EU implementation challenging. The EACB acknowledges the Commission’s efforts to reduce the expected impact of reforms on the EU banking and credit markets and economy, while remaining compliant with the spirit of the global agreement, but further efforts are necessary. As the first major jurisdiction to unveil implementation plans, a 2025 start date and a sufficiently phase-in are absolutely necessary given the massive efforts expected from EU banks and the uncertainty around plans elsewhere. Banks will calculate and disclose “fully loaded” CRR3 ratios before the end of phase-in, becoming bound to fully loaded requirements ahead of time. A sign of capital shortfall at the end of transitionals would negatively impact investor confidence early on, affecting banks’ ability and need to raise capital (or bail-in debt) and restricting lending capacity. The transitional arrangements for residential real estate, unrated corporates and SA-CCR reflect key EU specificities, they should be extended to the standardized approach. A phase-out should be conditioned to structural changes of EU markets far to be seen. Arguments like low ratings coverage of EU corporates, recognizing low risk mortgages, allowing EU corporates to hedge their business risks at reasonable cost apply, and so do operational reasons: two standardized approaches add complexity and operational costs (double calculations). Banks would also see a hike in RWAs at the end of transitionals unjustified from a risk perspective, especially for long-term exposures (eg mortgages). We strongly support the proposal to only apply the output floor (OF) at the highest level of consolidation. The SSM chair repeatedly warned that, if the OF were to be applied at solo level, the EU banking market would fragment further and reduce banking groups’ flexibility to allocate capital internally. Moreover, the cap under Art. 465 CRR, for floored RWAs not to increase more than 25% vs. pre-floor, should be set at 10%: this was the G20 mandate, reaffirmed also by the European Parliament. We strongly support the 100% risk weight (RW) for equity exposures within a group or an institutional protection scheme according to Art. 49(4) CRR: this is essential to the well-functioning of cooperative groups and networks. The possibility to assign 100% RW for “strategic” equity exposures to entities where institutions have been shareholders for six consecutive years is key (Art. 495a Para 3 CRR). This should be further refined: a 100% RW for strategic holdings should apply regardless of earlier approach and be solely based on the strategic criteria. It would ensure a level playing field across banks and Member States and be reasonable from a risk perspective (same treatment for a holding becoming long term, 100% RW, in 2024 or in 2026). The aim to further embed proportionality in the framework, producing disclosures of small and non-complex institutions directly at the EBA via reporting sets, is appreciated. However, this contrasts with the proposed extension of ESG disclosures to SNCIs. Further proportionality elements could be envisaged. With regard to operational risk, in addition to a general ILM=1 it should be specified that where banks have the capacity to calculate their ILM they must have the possibility to do so. Finally, the choice to preserve the SME and infrastructure supporting factors is vitally important and appreciated, especially since other elements might lead to reduced credit supply. The same applies to the CVA exemptions. The choice not to implement a hard granularity criterion for the retail portfolio is appropriate, allowing smaller banks not to be put at a disadvantage. For overall balance, discussions should progress jointly on all legal acts – see comment on the CRD Have your say.
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Response to New EU system for the avoidance of double taxation in the field of withholding taxes

26 Oct 2021

The members of the European Association of Co-operative Banks (EACB) gladly take the opportunity to comment on the European Commission’s roadmap consultation “New EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes”. We appreciate the Commission’s efforts to explore possible solutions to the withholding tax relief procedures for cross-border investors, which are currently burdensome and costly, entail double taxation and hamper cross-border investments in the EU. Of the options mentioned in the Inception Impact Assessment, the EACB Members support the establishment of a standardized EU-wide system for withholding tax relief at source, which is Option 2 of the current EU initiative. Due to the Common Reporting Standard (CRS) for the Automatic Exchange of Information in tax matters, financial institutions need to know anyway whether a customer can claim at-source relief from withholding tax. Furthermore, in addition to the issuers of the security, those obliged to deduct taxes should also be added. If this option fails to be implemented, EACB would then support improving withholding tax refund procedures to make them more efficient, as stated under Option 1. We believe that faster, more efficient and more transparent procedures can also provide relief. In this respect, withholding tax refund procedures should use standardized forms and should be based on the common definitions and processes throughout the EU. Such single forms, translated in all EU languages, with the single address in each Members State, would allow to swiftly simplify current procedures for refund. We would also welcome the development of digitized processes (such as single electronic form or a single website) in order to speedily facilitate the creation of a standardized and efficient relief at source system. Incidentally, in its deliberations, the EU should make sure to take into account the experience gained at the OECD level in the Tax Relief and Compliance Enhancement (TRACE) project in order to achieve international compatibility. For instance, with the view to improve the procedures for tax relief for cross-border investors and making refund system more efficient, several measures have been discussed, such as maintaining a central office for such claims, and working towards standardizing such procedures across the European Union and OECD. Moreover, countries should develop consistent “quick refund” procedures pursuant to which withholding agents themselves are permitted to adjust initial over-withholding, rather than requiring investors to make a refund claim to the government in such cases. While the Commission refers to a case of abuse of current procedures and cites a large-scale tax fraud known as “Cum/Ex” scheme, it however remains unclear from the Inception Impact Assessment how an introduction of EU system for tax relief at source would prevent such cases which stem from tax loopholes within national law.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and Rabobank

22 Sept 2021 · Capital requirements and green transition

Response to Quick Fix to the UCITS Directive

9 Sept 2021

The European Commission recently adopted amendments to the Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation and the Undertakings for Collective Investment in Transferable Securities (UCITS) Directive. However, in contrast to earlier plans, the adoption of the revised Regulatory Technical Standards (RTS) amending Commission Delegated Regulation (EU) 2017/653 has been postponed. Despite this fragmented process, the European Commission is proposing to maintain 1 July 2022 as the date of application of the new requirements to all product manufacturers, including those offering multi-option products (MOPs) with UCITS as underlying investment options. The unexpected delay in the adoption of the revised PRIIPs RTS would cut the implementation period for the industry by three months. This leaves PRIIPs manufacturers and distributors with only nine months instead of the original timeframe of 12 months to implement the new rules. The European Fund and Asset Management Association (EFAMA), European Association of Co-operative Banks (EACB) and European Savings and Retail Banking Group (ESBG) are, therefore, asking the European co-legislators to ensure that the financial industry has a reasonable twelve months to implement the new rules by 31 December 2022 (instead of 1 July 2022). This request for postponement is based on the assumption that the revised RTS are published in the EU Official Journal, at the very latest, by 31 December 2021. To follow through on this request, the timelines in the PRIIPs and UCITS quick fixes must be aligned: With regards to the UCITS ‘quick fixes, we are, asking the European co-legislators to change Article 2 to allow Member States until 31 December 2022 (instead of 30 June 2022) for the adoption and the publication of the measures, and that these come into effect from 1 January 2023 (instead of 1 July 2022). Moreover, the requirement to produce a UCITS KIID is maintained for professional investors. We regret this approach, as professional investors do not require the same level of protection as retail investors; they get much more detailed information, and more frequently, tailored to their needs. Maintaining the UCITS KIID for institutional investors will cause unnecessary costs and efforts, which would be needed for other projects or initiatives. Bearing in mind the goals of an efficient Capital Markets Union in Europe, we invite the European legislators to consider abolishing the UCITS KIID (and PRIIPs KID) for professional investors. Should professional investors even have the choice to receive a UCITS KIID or PRIIP KID, a PRIIP KID may need to be produced for professional investors, which is contrary to the wording of the PRIIPs Regulation (such as Recital 7 which states that “Investment funds dedicated to institutional investors are excluded from the scope since they are not for sale to retail investors.”) and which would create unnecessary costs. To date, no PRIIPs KIDs are produced for share classes reserved for professional investors and also professional investors do not receive a PRIIPs KID since the obligation is only triggered where the product is bought by a retail investor.
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Response to Quick fix to the PRIIPs Regulation

9 Sept 2021

The European Commission’s proposal to maintain 1 July 2022 as the date the new Level 1 and Level 2 requirements apply to all product manufacturers, despite the delay in publication of the RTS, cuts the implementation period for the industry by more than 2 months. The proposed implementation period is too short, especially for new rules that relate to communication with investors and potential investors. To achieve better trust and understanding among investors and potential investors, the market needs time to adapt and get it right first time and avoiding confusion, to the detriment of consumers and Europe’s economy. Implementing changes involves numerous departments and competences to interpret the new requirements; gather new data; make actuarial and financial calculations; properly plan and make changes to IT; redesign templates; test the calculations and design; legally assess the narratives and figures; translate them; adapt training for staff and distributors; and implement new website disclosure requirements, etc. The many stakeholders in the value chain are involved in implementation. Many PRIIPs sold by insurers are MOPs that provide investors with a combination of different underlying funds. Where these are UCITS, insurers need the data and documents produced by UCITS providers to comply. As the new rules apply to both insurers and UCITS providers, MOPs providers will need sufficient time to collect the data from UCITS providers — once available - and update all their existing pre-contractual information for MOPs, update and store all KIDs on their websites, etc. This requires extensive dialogue between insurers and asset managers to agree the practicalities of data exchanges. Too short an implementation period could lead to poor implementation or force operators to suspend the distribution of certain products, which would be detrimental to consumers’ participation in the capital markets and trust in the information they receive. To ensure an orderly implementation, we urge for a 12-month implementation period from the adoption of the RTS proposals as the minimum time needed for all products and all market participants. A synchronised application date for all products (IBIPs, UCITS, MOPs, etc.) and providers (insurers, asset managers, etc.) for both the Level 1 and Level 2 amendments is key. In particular, Article 18 of the current PRIIPs RTS - which allows insurers to rely on the derogation in Article 14(2) of the PRIIPs RTS and to use the UCITS KIIDs for the provision of information on underlying funds for MOPs - is independent of any changes to the date of application of the UCITS exemption. The extension of the UCITS exemption will therefore not prevent Article 14(2) from expiring in December 2021, as currently stated in Article 18. This would pose significant practical difficulties for providers currently making use of the derogation in Article 14(2), as they would be required to produce their own PRIIPs KIDs for each underlying fund by the end of this year. This would also entail a substantial compliance burden for insurers and asset managers. They would need to produce entirely new data to populate the PRIIPs KIDs by a deadline that is much too short, and where the data simply could not be produced on time, the range of products offered to consumers would ultimately decrease. To ensure a consistent transitional regime across providers, the necessary legal certainty while UCITS remain exempted from the PRIIPs Regulation and a smooth implementation of the new PRIIPs RTS, we therefore reiterate the importance to align the expiry date of Article 18 of the PRIIPs RTS with the new end date of the UCITS exemption. As the scrutiny of the revised RTS by the co-legislators will take some time, we would also appreciate an expedited procedure by the co-legislators to facilitate publication in the EU Official Journal as soon as possible.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

3 Sept 2021 · Basel III

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

31 Aug 2021

The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the draft implementing regulation on the designation of a statutory replacement for certain settings of CHF LIBOR as published by the European Commission on 3 August 2021. Our members had already fully supported by way of a public statement dated 11 June 2021 (see link in attached document), the designation of SARON compound rates according to the “last reset” methodology and a fixed spread adjustment as statutory replacement to CHF LIBOR. We thus reiterate our support in this regard and emphasise that this is the only solution to avoid the risk of contract frustration and significant market disruption, as most existing contracts (the majority concluded before 2010) do not include provisions for the event of LIBOR cessation. We also appreciate that several concerns raised in our public statement have been included in the draft implementing regulation, namely:- - Cut-off date of 5 March 2021 (UK FCA cessation announcement date) used for the spread adjustment value (SAV) calculation; - The SAV is directly fixed in the implementing act, and it is made clear that the SAV is to be published by Bloomberg as benchmark administrator; and - SARON compound rate on last reset methodology plus fixed SAV is now extended to other CHF LIBOR tenors (1-month, 6-month, 12-month). We also note that our members that are party to CHF LIBOR contracts must inform their counterparts of the change in the rate and the effects on their contracts in writing not later than 30 days before the statutory replacement rate starts to apply, but we consider this to be a reasonable requirement. The main discrepancy we noted is that recital 13 (which states that the statutory replacement applies to only “products such as savings accounts, mortgages and loans, including consumer credit agreements and small business loans, governed by the laws of one of the Union Member States, which do not contain suitable fall-back provisions") is narrower in scope compared to Article 1(1) of the implementing regulation (which states that the “rates are designated as replacement for the CHF LIBOR in references to CHF LIBOR in in contracts and financial instruments as referred to in Article 23a of Regulation (EU) 2016/1011”). The EACB supports the material scope under Article 1(1) of the implementing regulation and would thus advocate for recital 13 to be clarified in order to avoid any misinterpretations. In parallel to the wording in recital 13, we also would like to share our understanding that SARON as published in the implementing regulation can also be used as a replacement rate in case of cessation of contracts referencing CHF LIBOR, that have already foreseen (suitable) fall-back provisions. Finally due to the imminent cessation of CHF LIBOR and in order to maintain stable and functional financial markets, we support a timely publication of the final implementing regulation in the Official Journal of the European Union ideally before Q4 2021.
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Response to Designation of a statutory replacement rate for EONIA (Benchmark)

31 Aug 2021

The European Association of Co-operative Banks (EACB) has long been advocating for a legislative tool that would provide legal certainty for the transition from EONIA to €STR in already-existing financial contracts that would not mature before €STR becomes fully applicable on 3 January 2022 (References: links in attached document). We are thus very pleased and fully supportive that the European Commission has exercised its powers under Article 23a of Regulation (EU) 2016/1011 to designate €STR as published by the European Central Bank as the statutory replacement in contracts and financial instruments referencing EONIA, with the addition of the fixed spread adjustment equal to 8,5 basis points. We also appreciate the European Commission’s clarification that “any contract or financial instrument still referencing EONIA as of the date of its cessation is considered a “legacy contract” under this implementing regulation, and therefore falls under the scope of the statutory replacement measure”. The EACB believes that this is the best risk management measure in the event of serious contract frustration that could affect financial stability and legal liability across the EU, due to the many pending legacy contracts still referencing EONIA that could not be renegotiated before 3 January 2022 (EONIA to €STR transition cut-off date). In addition, this implementing regulation also provides the necessary legal certainty required by consumers and investors.
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Response to Requirements for Artificial Intelligence

23 Jul 2021

The European Association of Co-operative Banks (EACB) recognises that the AI proposal is the Commission’s first ever legal framework on the matter, which addresses the risks of AI and aims to position Europe to play a leading role globally. It should be recognised that this is a risky bet. If European values were not ultimately adopted on an international scale, European companies would be at a disadvantage compared to non-European players active in less restrictive regulatory environments. We believe that the European Commission, the European Parliament and the Council should remain vigilant to ensure that European players are not unduly constrained in their prospect of developing innovative AI solutions compared to international competitors. We would like to highlight the following points: • The EACB welcomes the Commission’s risk-based approach as basis for a proportionate legal text. • We appreciate the technology-neutral and future-proof definition of AI, recognising that AI is a “fast evolving family of technologies” that is constantly developing. Nevertheless, combining the definition of artificial intelligence system together with the techniques and approaches of Annex I of the proposal, we observe that the scope of the Regulation is becoming quite wide as it also includes rule-based approaches. • We believe it is of paramount importance to make sure that the AI proposal will not add new and burdensome requirements for the banking sector and create conflicts and overlaps with existing rules: e.g., sector-specific regulation (CRD, CRR). • Generally, some provisions of the Regulation contain somewhat vague wording, e.g., the definitions provided for “remote biometric identification system” and “user”. Moreover, we believe that the definition of ‘developer’ and ‘end user’ are missing from the legal text. These points should be further clarified in order to guarantee legal certainty for providers, developers and users of AI systems. • Regulatory sandboxes are useful for the development of AI. However, their objectives and entry criteria should be clear and made public in order to ensure a high degree of transparency and a level playing field in the entry process. • We wonder how AI systems can be prevented from being biased. This requirement is not realistic as it cannot be guaranteed that datasets will be fully correct or complete. We believe that errors should be minimised and that the training, validation and testing of the AI system should be as complete as possible. To ensure a fair treatment an ex-post revision should be made possible. Attached the EACB developed position paper.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

The EACB considers the CSRD extremely important for the full achievement of the sustainable finance framework and welcomes many of the proposals. Our answer to the consultation represents our co-op banks members’ views as both users and preparers of sustainability reports. Please see below our comments. - Scope: We support the proposed extension of the scope to cover non-EU companies and SMEs whose securities are admitted to trading on an EU trading venue. This is sensible for financial institutions to have access to standardized, reliable and comparable data. - Implementation timetable: In order to ensure that co-op banks and financial companies in general are able to perform their sustainability reporting, data from their clients must be available. Thus, we recommend the introduction of a one-year gap for the first reporting year between financial and non-financial corporates. This would mean that if the first NF corporate sustainability reports will be published according to CSRD in 2024, the sustainability reports of financial companies would have to be published in 2025. - International cooperation: We are pleased that the European Commission advocates the global convergence of reporting standards in the present draft. We support efforts in this regard. As EFRAG is already operationalising the requirement to create a Sustainability Pillar to draft sustainability standards and provide technical advices to the EU Commission and in the light of the international harmonisation foreseen we would expect more clarity on the future architecture of standards and on how it will be ensured that the two levels will be aligned and complementary. - The EACB agrees that in general assurance standards help increase the reliability of the data, especially from the perspective that financial undertakings disclosure depends on corporate clients sustainability data whose accuracy is at the core of the Sustainable Finance Framework. Furthermore, it is important that the assurance of sustainability reporting is for the time being carried out as a limited assurance engagement. We welcome the grandfathering clause benefiting Statutory auditors approved before 1.1.2023 but think this provision needs to be extended. The new requirements should only apply to auditors starting training after 1.1.2023, while existing professional licenses must remain unaffected. - We support the underlying reason to have machine-readable digital information and we appreciate the effort to make sustainability data available in the ESAP, in line with our proposal for a centralised EU ESG Data Register. However, the implementation of ESEF for financial statements has shown how complex it is to implement such requirements as the XHTML format puts additional burden on undertakings. We suggest envisaging an implementation period for digitalization of NF data that could be feasible and allow to fulfil the future requirements in a reasonable manner. MSs should ensure that the reporting requirements will be developed in a proportionate manner, avoiding excessive administrative burdens and costs. Especially for undertakings which are currently not in scope of the ESEF regulation, it might serve as possible solution to convert data into XHTML for free at an officially designated data register. - The management report shall give a true and fair view of the assets, liabilities, financial position and profit or loss. This means that important financial and NF KPIs must be disclosed in the management report in order to assess this situation. We do not consider a mandatory extension of the management report to include detailed sustainability information to make a difference: many entities publish separate sustainability reports which combine mandatory and voluntary information, to ensure an easier readability and avoid complexity. MSs MSs should be given the possibility to decide on this issue, according to the reporting practices already in place at national level.
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Response to Distance Marketing of Consumer Financial Services - Review of EU rules

24 Jun 2021

The EACB appreciates the technology neutrality of the DMFSD, which has allowed banks to develop and adapt distance marketing to different channels, reflecting new technologies and consumer expectations. Neutrality avoids the need to consistently adapt legislation. Specifying in the legislation how to adapt the information to different devices would not be technology neutral or scalable. Furthermore, the Unfair Commercial Practices Directive entails an obligation for clarity and intelligibility of information. The nature of pre-contractual information depends on the product and the Member State. Additionally, product-specific legislation has prescriptive information requirements. Before proposing requirements, we kindly invite the Commission to balance the burden and the benefits of new requirements as it appears that no systemic difficulties have been identified in this context. Right of withdrawal is well known by banks and consumers and it is sufficient to address the risk of the consumer being trapped in an unsatisfactory contract. Modifying this right does not offer more guarantees to consumers and is likely to cause disruptions without significant gains. We would rather encourage better respect of the foreseen principle by way of enforcement scrutiny. Further requirements on transparency on targeting practices means imposing new information obligations and this is already heavy and costly process. Many of these points are already covered by other horizontal and product-specific legislation (MiFID, IDD, GDPR, UTCCD etc.) Banks are obliged to explain relevant aspects of the process and ensure the adequacy of the product/service to the profile of the customer. Banks must ensure that a product/service is suitable to customer’s needs. Additionally, not all offers are unbeneficial for the customer, who can choose not to subscribe to the offer. This motivates banks to optimize their products and targeted marketing. Consumers are informed of the total price to be paid, or if the exact price cannot be indicated, the basis for calculation of the price, and of the possibility of taxes/costs. The DMFSD’s application does not generate fundamental problems and it serves its purpose as a horizontal legal framework and provides a high level of consumer protection, especially on the information requirements. Its added value is especially evident as a safety net for products that are not covered by product-specific legislation, ensuring the level of consumer protection. The EACB favors regulatory certainty as much as possible; We invite the Commission to clarify the interplay of DMFSD and product-specific legislation, by for example, making DMFSD subsidiary to the product-specific directives. The EACB supports a competitive and effective single market for retail financial services. However, the level of cross-border supply is due to the very low customer demand and other barriers e.g., language, cultural behavior, currencies, taxation, different civil laws, lack of harmonization of debt recovery proceedings, and gold-plating practices (DMFSD, CCD and other product-specific legislation) have fragmented the market. Policy options: The Directive has fulfilled its purpose of ensuring a high level of consumer protection, through a clear regulatory framework. It is short, simple, and agile and it copes well with evolution of markets and technology. We believe that a revision or a repeal of the DMFSD will not resolve the problems addressed above. Possible loopholes/problems derive from an incorrect implementation and enforcement of the text. We appreciate the will of the Commission to consider the costs of regulation which may be increased by gold-plating practices and IT investments. The focus should also be placed on regulatory implementation, enforcement, a level playing field and financial education. For above reasons, the EACB supports option 0, the baseline scenario.
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Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

18 Jun 2021 · Banking Union, CMU Basel III Digital finance Sustainable Finance

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Although the EACB welcomes the staged approach proposed by the EC in the draft delegated Act (DDA) Art. 8, we would like to raise remaining concerns. The first is that the obligations for financial undertakings (FU) require clients’ data that will only be disclosed by non-financial companies (NFC) in 2023. Thus, we propose a one year reporting gap between NFC and financial companies (FC). For FC disclosure shall start in 2024. A further one-year gap is necessary to integrate FC’s data in 2025. Alternatively, we ask FU’s compliance on best-effort basis in 2023-2025. The unavailability of NFC’s taxonomy data in 2022 affects also the SFDR disclosure (investment’s taxonomy alignment in 2022) and Pillar 3 (draft EBA ITS disclosure in June 2023 on 2022 data). Credit institutions need data from the real economy in a standardised audited format. Another concern is that many smaller clients and investees do not disclose taxonomy data (not in NFRD’s perimeter). Thus we recommend a materiality threshold in the DDA, for loans and investments to be subject to reporting if they exceed a certain threshold e.g. 10 million EUR, only then should they be included in the KPI denominators. This would allow for a focused Green Asset Ratio (GAR) of Credit institutions (CI) and GIR of Asset Managers, increasing feasibility especially for CI’s reporting related to SMEs and households. More in general, for non-NFRD (CSRD) companies Art 11.5 DDA provides voluntarily inclusion in the numerators of KPIs for FU from 1 January 2025. We warn about two risks: i) banks whose SMEs clients have difficulties to provide data may be penalised, ii) this would also decrease the consistency and comparability of the ratios between peers. Therefore, we ask for SMEs to be excluded from the GAR until the review foreseen in DDA art. 10 and consistency with CSRD can be ensured. Should EC maintain the voluntary approach and exposures in non-NFRD companies be included in the numerators of KPIs, the use of proxies and estimates (i.e. JRC´s methodology in EBA and ESMA´s TA) should be explicitly allowed. Banks operating in non-EU geographies could risk being differently treated compared to those that are only EU-based due to different level of GAR data availability. To avoid risk that investors compare banks with different profiles of activities and draw the wrong conclusions, we suggest calculating GAR for EU and non-EU assets separately. Since the taxonomy TSC will evolve over time, it is important that financial instruments which are Taxonomy-aligned at issuance don’t lose their status when the TSC are adapted -especially considering the long maturity of certain portfolio holdings and lending. However FU should have the opportunity to reassess the GAR when assets reach Taxonomy-alignment during the lifespan of the financial operation. Concerning the stock of loans, we ask to specify in DDA art. 9(3) that 2023 is the cut off date for credit institutions to start building up the required five years reporting periods in the KPIs. There should be no retroactive application. Only financings granted from the application date of Taxonomy disclosure can be considered. Complete alignment of GAR disclosure under Art 8 Taxonomy and the EBA ITS shall be ensured. Given that the templates have different formats currently, we fear that this could lead to a parallel disclosure that would undermine transparency, confuse investors while adding complexity and inefficiency. For KPIs we highlight the issue of calculations consistencies. Should certain exposures, and products be excluded from the numerators but not from the denominators, this would affect the KPIs (lowering them), hence their usability. We question the general complexity of the templates and if they are fit for purpose (see annex). Finally, we ask for clarification on art.11.2(a) for reporting the taxonomy eligibility assessment in 2022 by FU, with no clarification on methodology, comparability issues may arise.
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Response to Social Economy Action Plan

26 Apr 2021

The members of the European Association of Cooperative Banks welcome the plans of the European Commission for an Action Plan on Social Economy. Cooperative Banks with about 60 million members, around 190 million clients and about 650000 employees stand for one of the strongest cooperative sectors in the EU. While not all of our members would understand themselves as a part of an economy they would call “social”, they all strongly support and adhere to the cooperative principles. For cooperative banks, one of the priorities of the action plan should be to enhance the visibility of cooperatives as well as understanding of their specific features and positive impact on society and the environment among the general public, policy makers and also regulators. An important element would be to strongly promote that the cooperative form of enterprise is integrated into the relevant curricula for economic education in schools and universities. Our conclusion from decades of advocacy for cooperatives is that the knowledge on cooperatives in wide parts of the population (and all levels of education) is rather poor. Overcoming this ignorance would be crucial. This would also be an important precondition to ensure that the legal form of a cooperative is accepted as fully equivalent to other forms of companies. As regulated entities cooperative banks see themselves again and again in a struggle for the acceptance of cooperative particularities and for adjusted rules. As the knowledge about cooperatives and the awareness of their existence is not so common, hardly anybody thinks of cooperatives when new rules are made. However, it is this ignorance that discriminates. In particular, it must be ensured that that the Single European Rulebook as the foundation of the Banking Union does not promote a single business form or corporate governance model. We also strongly support the idea that the understanding of the positive impact of cooperatives on society and environment should be enhanced. However, this is not enough. The current discussions on sustainability, e.g. related to a “social taxonomy”, should be used to definitely determine that the cooperative legal form, i.e. the cooperative governance elements are by themselves contributing to a sustainable and people-oriented economy and thereby contribute to the Sustainable Development Goals (SDGs). In fact, we realized repeatedly that inherent elements of cooperative governance are seen negative, like the member involvement in the boards of cooperatives (as board members are not independent) or the broad ownership combined with democratic voting (“weak” governance, no reference shareholder). These approaches see the price of cooperative governance, but not its values. We therefore believe that it is important to get this fixed. We also believe that the cooperative model should be promoted through international fora and networks, and especially its contribution to the Sustainable Development Goals (SDGs). In fact, idea and practice of organizing shared interests in cooperatives was inscribed on the Representative List of the Intangible Cultural Heritage of Humanity. This acknowledgment underlines the universality of the cooperative model and the value it can create in societies around the world. We therefore encourage the European Commission to promote it also on a global level, where suitable. Please find in the annex a paragraph on the legal form of cooperatives and the advantages of the specific cooperative governance.
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Meeting with Mairead McGuinness (Commissioner)

13 Apr 2021 · Basel 111 Corporate Management Covid-19 & EU response Banking Union

Response to Instant Payments

7 Apr 2021

Attached please find findings from the survey performed among our member organizations.
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

16 Mar 2021 · Preparation of Commissioner McGuinness at EACB Board Meeting

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

15 Feb 2021

Please find attached the position paper of the European Association of Co-operative Banks to the Commission's proposal on digital operational resilience for the financial sector.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The EACB believes that the implementation of the criteria proposed in the delegated acts to the Taxonomy Regulation will play an important role in creating a uniform EU-definition of environmentally sustainable economic activities. However, we believe that (as shown on the example of the categories and activities below) the proposed draft technical screening criteria should be improved to safeguard an easy usability, avoiding inconsistencies due to the lack of clarity in wording and generally we argue to limit the many cross references present in the report. . On the building sector, we believe the new wording “For buildings built before 31 December 2020, the building has at least Energy Performance Certificate (EPC) class A” (page 203, Annex I) represents a critical challenge, which contradicts the concept introduced in the final report of the TEG. If this new proposal will be integrated in the official delegated act to the taxonomy regulation, it will represent a significant obstacle for a large number of buildings to be eligible according to the criteria for environmentally sustainable activities. We cautioned that the proposed requirement of energy label A would weaken the applicability of the Taxonomy and therefore slow down both the harmonization and promotion of green financing. To better understand the impact it might have, some of our members have quantified the reduction in houses' eligibility under the new wording (compared to the previous one) at around 90-95 %. This can lead to a 'de facto' disappearance of incentives for banks and borrowers to favor better houses within the building stock when taking the purchasing (and financing) decision, something against the objectives of the EU environmental agenda, and thus failing to impulse housing renovation. . Moreover, it should be noted that the '15% best' criterium is already a moving target, an objective that will become more demanding as time passes by, thus creating a positive trend towards higher requirements as the building stock is being renewed, and its average energy efficiency improves. That is why the '15% best' approach should not be taken as an easy target, or a threshold that risks creating stranded assets or lacking the needed incentives to improve energy efficiency. . The Taxonomy was supposed to take into account existing market practices that would make it easier to use and ensure it is aligned with existing green bond frameworks. However, if the criterion “energy label A” is applied, the Taxonomy will significantly diverge from existing market practices and current Green Bond market in Europe. . Similarly, since the vast majority of the DNSH criteria was built on existing EU regulations, the DNSH criteria should be such that fulfilment is easy to check for large numbers of buildings. At the moment for some DNSH criteria there is no data available to check whether a building fulfils the criteria or not. . Eligibility criteria for new buildings (i.e. built after December 2020) are based on a Primary Energy Demand 20% lower than the NZEB requirements. In many EU countries, the NZEB requirements are already very ambitious. The proposed wording doesn’t specify how the extra 20% of energy performance would be calculated when buildings already have a negative net energy consumption. In that respect, the TEG recommended in its final report no additional requirement where the local regulation is already net-zero carbon aligned (p. 372, Technical appendix). We would recommend using just the NZEB standard without additional requirements. . For all these reasons, we believe the Taxonomy can promote green financing if, and only if, the criteria are achievable for a reasonable amount of assets. With the proposed change in criteria, the Taxonomy will not really incentivise financing of residential buildings. A deeper analysis is included in the EACB position paper here attached.
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Response to Review of the Benchmark Regulation

5 Oct 2020

The EACB welcomes this opportunity to provide feedback to the European Commission's proposal to amend the EU Benchmarks Regulation (BMR). We understand that the proposed Delegated Act is a sort of quick fix solution, which is important due to current critical events such as the cessation of LIBOR without an adequate replacement and the COVID-19 pandemic. However, we also provide some feedback in our position paper that goes over and above the Commission's targeted amendments and hope that these are at least considered within the wider BMR review. These include the functioning of the EU benchmarks register, the power of national competent authorities and clarification of definitions within the Regulation. Regarding the proposed amendments, our position paper elaborates on the following main areas:- 1) Scope of the Delegated Act: There is a need for clarification of the material and territorial scope of the proposal as a minimum, but also of new contracts. The latter should be able to also make use of the statutory replacement rate if considered economically feasible in case of a trigger event. In addition, the scope of already established replacement rates should be clarified, e.g. statutory replacement for EONIA in legacy contracts is already established as €STR, and that €STR + 8.5bp spread is accepted as a replacement for “tough legacy contracts”; 2) Functioning of statutory replacement power in the Delegated Act: There are still many clarifications to be ironed out in this regard including applicability of trigger events to activate the statutory power, how the Commission will exercise its implementing powers, and the opt-in possibilities. We are of the view that the Commission should be empowered not only to define the replacement benchmark but also its application method (if necessary due to different characteristics and currencies/tenors of the replacement benchmark). The risk-free rate working groups should be able to identify different statutory replacement rates depending on the product type, but the Commission should have the power to intervene in situations where the working groups do not give clear recommendations on which rates should be used for which products. The general public should also be allowed (if possible) to provide feedback on the proposed alternative rate(s). Furthermore, it is important that the European Commission takes into account issues with the voluntary opt-in of contracts that already have a suitable fallback rate. The fact that a contract already provides a fallback clause does not necessarily mean it is free from litigation risk. We also would like to highlight that co-ordination is required when it comes to national measures by NCAs complementing the proposal, as well as, the risk of increased obligations on supervised entities which are beyond their capacity; 3) Proposed exemption of Spot Foreign Exchange Rate: The EACB suggests a wider definition within scope when it comes to spot foreign exchange rates.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

The EACB would like to emphasize the following points: o When specifying the requirements for entities subject to the Non-Financial Reporting Directive (NFRD) we support the initiative of the European Commission to differentiate between non-financial and financial undertakings in the taxonomy regulation by taking into account their specifities, as business activities and accounting of non-financial and financial undertaking are different. Without data from their clients’, financial institutions will not be able to assess their portfolios with regards to ESG performance. Financial institutions will therefore use information published by their clients at year 1, in order to complete their reporting for year 2. It is therefore necessary to defer the publication of information by financial institutions by 1 annual exercise after the reporting of non-financial companies. In practice this would mean that if corporate (our clients) would report as of January 2022, banks and financial companies could use these data for reporting not before January 2023. o We welcome the approach taken in the inception impact assessment by the Commission, needed to assess the workability and usability of the indicators. Indeed this new reporting is likely to have an impact especially on smaller cooperative banks (if included in the scope of the NFRD) in terms of costs, internal assets reclassification, IT system and organisation structure. In order to report, i.e. the percentage of green loans, our banks would have as pre-requisite to rely on clients’ “taxonomy aligned” data. However, our co-op banks clients’ portfolio is mostly composed of SMEs who do not report those data, nor have the capacity to do so. We thus urge the Commission to take data issues into account and ensure that the indicators to be defined for financial companies and specifically for banks are practical, clear, reliable and efficient. Indeed, the indicator should be narrowed down to the banking assets for which the information from customers is available and reliable. This means that entities excluded from the revised NFRD scope should not be included in the ratio. o The scope of the indicators should also be reduced as much as possible to ensure it is applicable, meaningful and comparable. A misinterpretation in the form of “what is not green is brown and harmful” should be avoided: o Therefore, we suggest the creation of a set of indicators to be used in combination, if lending as well as investments should be included in the scope. One indicator will identify the percentage as the share of the total assets on the balance sheet which is made of securities and loan borrowers which are subject to the obligations defined by the NFRD. Within this portion, we suggest to use as another indicator the percentage of taxonomy compliant assets. This will guarantee better comparability of meaningful data between banks who finance mainly large corporates (already under the scope of the NFRD) and retail/cooperative banks who finance a large amount of small clients (who are not included in the scope of the NFRD and do not provide non-financial / taxonomy aligned information). o Furthermore, the scope of the ratio should be reduced by excluding assets for which the application of the taxonomy makes no sense: e.g. reserves in central banks, trading books, hedging derivatives, sovereign debt with no use of proceeds, etc. o We would suggest a phase-in and “future-looking” approach, according to which only the flow should be reported (ratio should only refer to new business). o Due to the high correlation between the taxonomy regulation and the announced revision of the NFRD regulation, consistency with other reporting frameworks (Disclosure Regulation, Pillar III Disclosure) is necessary. In fact, a more standardized form of reporting could be introduced by the revised obligations of the NFRD.
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Response to Integration of sustainability risks and factors in relation to insurance undertakings and insurance distributors

6 Jul 2020

The EACB welcomes the opportunity to provide its feedback on the draft delegated acts to MiFID II, UCITS Directive, AIFMD, and IDD stemming from the goals of the European Commission’s ‘Action Plan: Financing Sustainable Growth’ to (i) integrate sustainability within investment advice (Action 4); and (ii) clarify the integration of sustainability in so-called fiduciary duties (Action 7). Our members as co-operative banks mainly provide investment advice for and portfolio management in financial products within the scope of MiFID II, and thus, are particularly focused on the distributors’ obligations to the client and the relationship with the product manufacturer in this regard. However, we also see it relevant to provide our comments on the delegated acts of the other directives so as to ensure a harmonised approach in line with the Better Regulation Agenda. Our detailed comments can be found in the attached annex.
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Response to Integration of sustainability risks and factors for undertakings for collective investment in transferable securities

6 Jul 2020

The EACB welcomes the opportunity to provide its feedback on the draft delegated acts to MiFID II, UCITS Directive, AIFMD, and IDD stemming from the goals of the European Commission’s ‘Action Plan: Financing Sustainable Growth’ to (i) integrate sustainability within investment advice (Action 4); and (ii) clarify the integration of sustainability in so-called fiduciary duties (Action 7). Our members as co-operative banks mainly provide investment advice for and portfolio management in financial products within the scope of MiFID II, and thus, are particularly focused on the distributors’ obligations to the client and the relationship with the product manufacturer in this regard. However, we also see it relevant to provide our comments on the delegated acts of the other directives so as to ensure a harmonised approach in line with the Better Regulation Agenda. The key messages we wish to convey are that: - SFDR and Taxonomy should lead the way in terms of sustainable finance: In no way should such Level II amendments under the various sectoral legislation over-ride the basis for sustainable finance already established under the published Regulation (EU) 2019/2088 (“SFDR”) and Regulation (EU) 2020/852 (“Taxonomy Regulation”), in particular relating to terminologies (e.g. definition of sustainability preferences and distinction between Article 8 and 9 SFDR products). The only instances where the consideration of sectoral legislation is explicitly stated with respect to directives, regulations, delegated acts and regulatory technical standards, is within the “financial impact” of sustainability risks (recital 14 SFDR) and their integration in remuneration policies (Article 5 SFDR), marketing communications (Article 13 SFDR), supervision by NCAs (Article 14 SFDR) and the document in which pre-contractual disclosures and periodic reporting can be made (Article 6(3) and Article 11(2) SFDR and Article 7 Taxonomy). The risk of maintaining these inconsistencies or over-riding the SFDR and Taxonomy is that the different sets of obligations could create complexity for the client and the business. Transparency only works in terms of investor protection if the client is not overloaded with information and is able to understand the disclosures presented in a simple manner; - Alignment with MiFID II/ MiFIR review: The Commission would also do well to consider the proposals made by all stakeholders during the consultation period on the review of MiFID II/ MiFIR conducted in Q1-12 2020, particularly with respect to product governance provisions and the suitability assessment. For example, the obligations between financial and sustainability characteristics, objectives and preferences should be cohesively implemented – failure to do so would mean repeating systems and documentation updates which is time consuming, costly and confusing for both investors and financial entities. Therefore, any proposals from the MiFID II/ MiFIR review which are eventually adopted should also be mirrored in the context of sustainable finance with the exception of the concept of the negative target market; and - Timing: We also believe that for the same reasons stated above, it is only fair to ask for alignment with respect to timing of implementation of the draft delegated acts with the upcoming regulatory amendments under the holistic review of MiFID II and MiFIR. Implementation deadlines of the draft delegated acts should also be aligned with the SFRD, Taxonomy, NFRD and Climate Benchmarks Regulation. Our further detailed comments can be found in the attached annex.
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Response to Integration of sustainability risks and factors related to alternative investment fund managers

6 Jul 2020

The EACB welcomes the opportunity to provide its feedback on the draft delegated acts to MiFID II, UCITS Directive, AIFMD, and IDD stemming from the goals of the European Commission’s ‘Action Plan: Financing Sustainable Growth’ to (i) integrate sustainability within investment advice (Action 4); and (ii) clarify the integration of sustainability in so-called fiduciary duties (Action 7). Our members as co-operative banks mainly provide investment advice for and portfolio management in financial products within the scope of MiFID II, and thus, are particularly focused on the distributors’ obligations to the client and the relationship with the product manufacturer in this regard. However, we also see it relevant to provide our comments on the delegated acts of the other directives so as to ensure a harmonised approach in line with the Better Regulation Agenda. The key messages we wish to convey are that: - SFDR and Taxonomy should lead the way in terms of sustainable finance: In no way should such Level II amendments under the various sectoral legislation over-ride the basis for sustainable finance already established under the published Regulation (EU) 2019/2088 (“SFDR”) and Regulation (EU) 2020/852 (“Taxonomy Regulation”), in particular relating to terminologies (e.g. definition of sustainability preferences and distinction between Article 8 and 9 SFDR products). The only instances where the consideration of sectoral legislation is explicitly stated with respect to directives, regulations, delegated acts and regulatory technical standards, is within the “financial impact” of sustainability risks (recital 14 SFDR) and their integration in remuneration policies (Article 5 SFDR), marketing communications (Article 13 SFDR), supervision by NCAs (Article 14 SFDR) and the document in which pre-contractual disclosures and periodic reporting can be made (Article 6(3) and Article 11(2) SFDR and Article 7 Taxonomy). The risk of maintaining these inconsistencies or over-riding the SFDR and Taxonomy is that the different sets of obligations could create complexity for the client and the business. Transparency only works in terms of investor protection if the client is not overloaded with information and is able to understand the disclosures presented in a simple manner; - Alignment with MiFID II/ MiFIR review: The Commission would also do well to consider the proposals made by all stakeholders during the consultation period on the review of MiFID II/ MiFIR conducted in Q1-12 2020, particularly with respect to product governance provisions and the suitability assessment. For example, the obligations between financial and sustainability characteristics, objectives and preferences should be cohesively implemented – failure to do so would mean repeating systems and documentation updates which is time consuming, costly and confusing for both investors and financial entities. Therefore, any proposals from the MiFID II/ MiFIR review which are eventually adopted should also be mirrored in the context of sustainable finance with the exception of the concept of the negative target market; and - Timing: We also believe that for the same reasons stated above, it is only fair to ask for alignment with respect to timing of implementation of the draft delegated acts with the upcoming regulatory amendments under the holistic review of MiFID II and MiFIR. Implementation deadlines of the draft delegated acts should also be aligned with the SFRD, Taxonomy, NFRD and Climate Benchmarks Regulation. Our further detailed comments can be found in the attached annex.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

The EACB welcomes the opportunity to provide its feedback on the draft delegated acts to MiFID II, UCITS Directive, AIFMD, and IDD stemming from the goals of the European Commission’s ‘Action Plan: Financing Sustainable Growth’ to (i) integrate sustainability within investment advice (Action 4); and (ii) clarify the integration of sustainability in so-called fiduciary duties (Action 7). Our members as co-operative banks mainly provide investment advice for and portfolio management in financial products within the scope of MiFID II, and thus, are particularly focused on the distributors’ obligations to the client and the relationship with the product manufacturer in this regard. However, we also see it relevant to provide our comments on the delegated acts of the other directives so as to ensure a harmonised approach in line with the Better Regulation Agenda. The key messages we wish to convey are that: - SFDR and Taxonomy should lead the way in terms of sustainable finance: In no way should such Level II amendments under the various sectoral legislation over-ride the basis for sustainable finance already established under the published Regulation (EU) 2019/2088 (“SFDR”) and Regulation (EU) 2020/852 (“Taxonomy Regulation”), in particular relating to terminologies (e.g. definition of sustainability preferences and distinction between Article 8 and 9 SFDR products). The only instances where the consideration of sectoral legislation is explicitly stated with respect to directives, regulations, delegated acts and regulatory technical standards, is within the “financial impact” of sustainability risks (recital 14 SFDR) and their integration in remuneration policies (Article 5 SFDR), marketing communications (Article 13 SFDR), supervision by NCAs (Article 14 SFDR) and the document in which pre-contractual disclosures and periodic reporting can be made (Article 6(3) and Article 11(2) SFDR and Article 7 Taxonomy). The risk of maintaining these inconsistencies or over-riding the SFDR and Taxonomy is that the different sets of obligations could create complexity for the client and the business. Transparency only works in terms of investor protection if the client is not overloaded with information and is able to understand the disclosures presented in a simple manner; - Alignment with MiFID II/ MiFIR review: The Commission would also do well to consider the proposals made by all stakeholders during the consultation period on the review of MiFID II/ MiFIR conducted in Q1-12 2020, particularly with respect to product governance provisions and the suitability assessment. For example, the obligations between financial and sustainability characteristics, objectives and preferences should be cohesively implemented – failure to do so would mean repeating systems and documentation updates which is time consuming, costly and confusing for both investors and financial entities. Therefore, any proposals from the MiFID II/ MiFIR review which are eventually adopted should also be mirrored in the context of sustainable finance with the exception of the concept of the negative target market; and - Timing: We also believe that for the same reasons stated above, it is only fair to ask for alignment with respect to timing of implementation of the draft delegated acts with the upcoming regulatory amendments under the holistic review of MiFID II and MiFIR. Implementation deadlines of the draft delegated acts should also be aligned with the SFRD, Taxonomy, NFRD and Climate Benchmarks Regulation. Our further detailed comments can be found in the attached annex.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

The EACB welcomes the opportunity to provide its feedback on the draft delegated acts to MiFID II, UCITS Directive, AIFMD, and IDD stemming from the goals of the European Commission’s ‘Action Plan: Financing Sustainable Growth’ to (i) integrate sustainability within investment advice (Action 4); and (ii) clarify the integration of sustainability in so-called fiduciary duties (Action 7). Our members as co-operative banks mainly provide investment advice for and portfolio management in financial products within the scope of MiFID II, and thus, are particularly focused on the distributors’ obligations to the client and the relationship with the product manufacturer in this regard. However, we also see it relevant to provide our comments on the delegated acts of the other directives so as to ensure a harmonised approach in line with the Better Regulation Agenda. The key messages we wish to convey are that: - SFDR and Taxonomy should lead the way in terms of sustainable finance: In no way should such Level II amendments under the various sectoral legislation over-ride the basis for sustainable finance already established under the published Regulation (EU) 2019/2088 (“SFDR”) and Regulation (EU) 2020/852 (“Taxonomy Regulation”), in particular relating to terminologies (e.g. definition of sustainability preferences and distinction between Article 8 and 9 SFDR products). The only instances where the consideration of sectoral legislation is explicitly stated with respect to directives, regulations, delegated acts and regulatory technical standards, is within the “financial impact” of sustainability risks (recital 14 SFDR) and their integration in remuneration policies (Article 5 SFDR), marketing communications (Article 13 SFDR), supervision by NCAs (Article 14 SFDR) and the document in which pre-contractual disclosures and periodic reporting can be made (Article 6(3) and Article 11(2) SFDR and Article 7 Taxonomy). The risk of maintaining these inconsistencies or over-riding the SFDR and Taxonomy is that the different sets of obligations could create complexity for the client and the business. Transparency only works in terms of investor protection if the client is not overloaded with information and is able to understand the disclosures presented in a simple manner; - Alignment with MiFID II/ MiFIR review: The Commission would also do well to consider the proposals made by all stakeholders during the consultation period on the review of MiFID II/ MiFIR conducted in Q1-12 2020, particularly with respect to product governance provisions and the suitability assessment. For example, the obligations between financial and sustainability characteristics, objectives and preferences should be cohesively implemented – failure to do so would mean repeating systems and documentation updates which is time consuming, costly and confusing for both investors and financial entities. Therefore, any proposals from the MiFID II/ MiFIR review which are eventually adopted should also be mirrored in the context of sustainable finance with the exception of the concept of the negative target market; and - Timing: We also believe that for the same reasons stated above, it is only fair to ask for alignment with respect to timing of implementation of the draft delegated acts with the upcoming regulatory amendments under the holistic review of MiFID II and MiFIR. Implementation deadlines of the draft delegated acts should also be aligned with the SFRD, Taxonomy, NFRD and Climate Benchmarks Regulation. Our further detailed comments can be found in the attached annex.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

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

14 May 2020 · Roundtables with Stakeholders; Capital Requirements Regulation

Response to Climate change mitigation and adaptation taxonomy

26 Apr 2020

- We urge to ensure that the practical work with the provisions of the taxonomy will be easy, clear, reliable and efficient to avoid unnecessary and costly administrative barriers. More details would need to be clarified, like the process for the establishment of the technical screening criteria on the climate change adaptation, still too complex to be implemented and applied (especially for small and medium-sized companies). Indeed, the technical screening criteria (as elaborated by the TEG) for the “climate change adaptation” seem too difficult to apply in practice, also due to the lack of available data. Hence, they should be considerably simplified in the course of the adaptation of the Delegated Acts. - Companies are not (yet) aware about the need of implementing specific additional information requested by the regulation. Undertakings (subject to the NFRD) shall include (in their non-financial statement) information on their activities associated with environmentally sustainable economic activities (% of their turnover and % of their CAPEX and/or OPEX). In our view, the timing of the new Taxonomy should be both ambitious because of the climate urgency and also realistic. This will not happen ‘over night’. In order to allow financial companies to collect the requested information from clients a phase-in period in the implementation of the new disclosure requirements should be provided. - As it is essential to have reliable and available data, we highly recommend to give financial institutions free access to already existing environmental and social data. The Commission should consider to develop an initiative that will allow to start collecting & providing the ESG data as already available in the market and reported by corporates in the EU in an electronic form under one of the main statistics centers in the EU. Such a database shall be open to companies which can insert – on a voluntary basis – ESG raw data. - On the building sector, even though the TEG proposals for “building renovation” are potentially achievable, the renewed house will not be considered as an energy efficient house after renovation, if it does not reach the general criteria for “acquisition of buildings” (cf. p.370 TEG’s technical annex EU taxonomy), which is materially impossible for older houses which are the ones most in need to renovate. The EACB believes that a renovated building, whose building code might correspond to the one applied decades ago, should have lower requirements in order to be considered within the Taxonomy after renovation. This would be the best path to incentivise renovations, which in our view are precisely the activities that may have the biggest positive impact in CO2 emissions reductions. Moreover, concerning new constructions, the Commission should avoid a relative linkage to national NZEB since from an investor perspective this may also lead to confusing conclusions as the exact same building could be classified as green in one jurisdiction and non-green in another jurisdiction. In jurisdictions with very high energy efficiency NZEB requirements, a further 20 pct. lower energy use may be hard to obtain. - The Commission will consider to extend the Taxonomy to social objectives. Cooperative banks in Europe are strongly committed to support the real economy at a local level. Their success depends largely on the economic, ecological and social wellbeing of their operating area. We believe that the creation of a clear classification of socially sustainable economic activities will help co-operative banks to better show how they are advanced in fostering social sustainability and proximity. - The EACB believes that the Platform should be composed of a broad range of stakeholders. Concerning the representation of the banking sector, it is of utmost importance that co-operative banks that are a significant component of the sector (20% market share) and essential contributors are properly represented in the new Platform.
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Response to Revision of Non-Financial Reporting Directive

27 Feb 2020

The EACB welcomes the Commission initiative to amend the requirements in the Non-Financial Reporting Directive in order to ensure that investors and other interested parties have access to the information they need, while not imposing excessive reporting obligations on companies. The EACB would like to emphasize the following points: - The Non-Financial Reporting impact on profitability, debt financing or even future regulatory burdens must be carefully addressed in order to avoid inconsistencies with other risk-related information disclosed by banks (eg art. 449a of the CRR II on the Disclosure of ESG risks). - The revision of the NFRD is the opportunity to introduce a common minimum set of data harmonized at EU level; that common set must be based on simple and credible KPIs and focus on materiality and comparability of the four main items: governance; strategy; risk management and metrics & targets. - Implementation of Non-Financial reporting requirements also leads to high processing costs, which binds relatively high personal capacities and financial resources especially in smaller co-operative banks. We therefore find it necessary to consider a flexible and gradual approach to the Non-Financial reporting requirements. We consider it crucial that an appropriate balance be ensured between the desired transparency and compliance costs for the undertakings concerned. Additional reporting requirements can be justified if the benefit of this information is clearly proven. - It is essential to have reliable and available data. We highly recommend to give financial institutions free access to already existing environmental and social data (eg. available in CDP). For this reason we would like to suggest that the Commission includes in the proposal an initiative that will allow to start collecting & providing the ESG data as already available in the market and reported by corporates in the EU in an electronic form, based on both aggregate and individual basis, under one of the main statistics centers in the EU (i.e. EUROSTAT). Such a database shall be open to non-financial corporate which can insert – on a voluntary basis – ESG raw data. Moreover, those data should be provided to users for free or at a reasonably affordable cost. The availability of high-quality ESG data should be regarded as a major strategic infrastructure investment project, which would enable more efficient work for mitigation of the climate change. Any data base must enjoy public credibility especially towards supervisory authorities. - The revised NFRD should ensure that the new rules provide the necessary data from corporate in the appropriate format so that banks can rely on them for the assessment of ESG risks. To ensure reliability of the reported data, we favor an external certification process. - Financial institutions cannot be entitled to disclose on the basis of data that the regulatory framework doesn’t allow them to retrieve from their clients. Since entities like SMEs (typically clients of local and regional co-operative banks) do not publish the requested information, it would be extremely difficult for banks to take the responsibility to guarantee a consistent and complete reporting (eg scope 3 information). It must be ensured that banks will not to be held responsible for not disclosing data that are not made available and sanctioned for non-compliance with the Disclosure Regulation and the Taxonomy Regulation. A 1-year delay in the entry into application of disclosure requirements could help financial institutions subject to the NFRD to achieve their obligations.
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Meeting with Valdis Dombrovskis (Vice-President) and

15 Nov 2018 · Implementation of PDS2, Benchmark Regulation, Banking Package

Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

The European Association of Co-operative Banks (EACB) is closely following the European Commission work on sustainable finance as this is a very important workstream for the EACB members due to the fact that co-operative banks, being local and regional banks, play a key role in sustainable financing. This is via sustainable investments or savings products, energy transition project financing, green financing to SMEs and energy efficiency financing of private and public buildings or via their social mission: reinvesting significant portions of available profits back into the community. Some co-operative banks are leaders in green bonds. Numerous awards for institutions from the cooperative banking sector are the evidence of this guiding role and also the daily financing of sustainable projects in various regions are part of our business model This being the case, the EACB and its members would like to once more stress that expressly support all political targets for creating sustainable and climate-friendly regulatory frameworks. These can be achieved via diverse measures to which public authorities, private households and companies should contribute. As the natural next step in achieving these goals, the European Commission published on 8 March its Action Plan on ‘Financing Sustainable Growth’ which was very much welcomed. In May 2018, the Commission adopted a package of measures implementing several key actions announced in its action plan on sustainable finance. One of these measures concerns a Proposal on amending the delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive (IDD) to include ESG considerations into the advice that investment firms and insurance distributors offer to individual clients. In this context, we support the need to raise awareness on this issue and are taking steps towards this direction. However, the EACB is concerned by the European Commission’s intention to amend the MiFID II and IDD delegated acts and the relevant ESMA’s guidelines in order to mandatorily incorporate ESG preferences and factors in the suitability test/process at this point in time. Other elements of the Commissions package such as the Taxonomy or disclosure requirements on how for example issuers integrate environmental, social and governance (ESG) factors in their risk processes (‘Disclosure & Investor Duty’), could be the starting point- that is more towards these issuers rather that non-professional retail investors. This is all the more so, as the first task would in any case have to be to include ESG information regarding the products (at asset manager level with details) that will allow to make the link with client’s preferences. Please see attached documents for our detailed comments. - Proposed way forward In order to do this right, avoid unintended consequences and market disruption, avoid unnecessary burden and costs, and ensure legal certainty we urge the European Commission to reconsidered its timetable for the implementation of the action plan on financing sustainable growth in this regard. Amending the delegated acts under the Markets in Financial Instruments Directive (MiFID II) and the Insurance Distribution Directive (IDD) to include ESG considerations into the advice that investment firms and insurance distributors offer to individual clients in a mandatory way should only be considered once a taxonomy has been established. We would urge the Commission to finish the taxonomy first and afterwards introduce amendments to the suitability requirements where necessary- allowing for enough time to implement these. A timeframe of at least 18 months from the time the taxonomy has been established would be considered adequate in that regard. Indeed, it is crucial to link the start of the transitional period to a complete Taxonomy.
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Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

23 Apr 2018 · ESAs review - Sustainable Finance

Response to Draft Delegated Act amending the Commission Delegated Regulation on the Liquidity Coverage Ratio ('LCR')

21 Feb 2018

The members of the EACB welcome the opportunity to comment on the Commission draft text for the amendment of the Delegated Regulation (EU) 2015/61 of 10 October 2014, i.e. the LCR delegated act. We truly appreciate that this exercise is done in a transparent manner and that the industry has the opportunity to submit feedback via a fully-fledged consultation. Overall we see that most of the adjustments are of a targeted nature and aim to address a number of elements that needed alignment with the international standards. However, some of the proposed amendments do not reflect such spirit and introduce questionable novelties while others require clarifications. In addition we would also call for amending the EBA LCR template only once the new delegated act is in force, and no longer than six months after, to avoid overlaps that may lead to uncertainty and undue reporting burden. As illustrated in more detail in the attached document, we would highlight the following elements: We have doubts on the introduction of the notion of connected clients in the context of the LCR, as from a liquidity perspective even connected clients may not show the same behaviour. We suggest clarifications in Art. 11 on the wording of time to maturity and in Art. 15 on the role of external auditors. We call for adjustments to the eligibility criteria proposed for securitisations and treatment of STSs, also to avoid that currently eligible items are abruptely no longer so with conséquences on the markets. More specifically we suggest: - Including securitisations complying with STS requirements into level 2A assets; - Maintaining the current parameters for level 2B securitisations (with some alignment with the STS criteria); - Including a new asset class within securitisations, namely ABCP issued by programmes fully supported complying with European Money Market Funds requirements. With regard to the amendment introduced in Art. 16 we believe it clarifies appropriately what was previously cross referenced with Art. 27, i.e. that deposits considered as liquid by the local banks of the cooperative group/network cannot be considered as operational and thus stable by the central body and vice versa. In this context, we draw attention to the fact that the EBA LCR template shall be amended on the basis of the revised wording of Art. 16(1). It must be borne in mind how the (liability-sided) liquidity reserve shall be disclosed in the future (e.g. among ‘non-operational deposits’). We also propose some adjustments to the wording of Art. 23 and 27 to the requirements on outflows, both to better reflect the economic rationale of certain transactions (Art. 23) and to avoid double counting in alignment with BCBS requirements (Art. 27). With regard to Art. 17, we welcome the introduction of the new paragraph 4. Nevertheless, there is no reason to restrict the waiver-option on Member States where systemic risks affecting the banking sector are materialising. Some of the sovereign and central bank programs for the middle asset class would also be responsible for negative LCR effects once coming to an end. Art. 17 (4) lit. b should be deleted. Finally, concerning Art. 4 the new paragraph (5)(b) “for items denominated in the reporting currency where the aggregate amount of liabilities denominated in currencies other than the reporting currency equals or exceeds 5% of the credit institution's total liabilities, excluding regulatory capital and off-balance sheet items, in the reporting currency.” provides in certain cases (e.g. for many institutions supervised by NCAs) for a new but unnecessary reporting burden with no use for supervisory purposes.
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Response to Review of the European Supervisory Authorities

23 Jan 2018

• The EACB fears that the proposals to give additional competencies to the ESAs regarding a “Supervisory Handbook” and a “Strategic Supervisory Plan” would mean a de facto first step towards a direct supervision by the ESAs of the national supervisory authorities and thus an indirect supervision of market participants- this needs to be avoided. • It needs to be ensured that the ESAs do not overstep their respective mandates and that delegated acts, implementing acts, technical standards, guidelines and Q&As strictly comply with the provisions of the Level 1 texts on which they are based. It is of utmost importance that the hierarchy between Level 1, Level 2 and Level 3 is fully respected by all EU authorities involved. It is equally crucial to have legal certainty and to avoid that Level 1 legislation is “corrected” or that “add-ons” are created by Level 2/Level 3 measures. The ESAs acting without prior mandate from the legislator can be problematic, as the democracy of the process is not fully ensured. For that we would suggest to: - Introduce an amendment requiring that a right to object to guidelines or recommendations is granted to EP and to Council before guidelines or recommendations are published (same procedure as for the RTS). We consider the proposed control of a decision of an executive authority by another executive authority to be problematic. In such cases, the EP and Council should rather be included as a democratically legitimated body. This applies in particular to situations in which the ESAs are not authorised in a Level 1 or Level 2 legal act for the adoption of Level 3 measures. - Introduce the right of legal review Level 3 measures (legal recourse mechanism). - We would encourage the ESAs to involve market participants throughout the preparation of their draft proposals– that is early enough and already in the beginning of the drafting process and not just with the "finished result" that is in many cases presented with consultations papers- and maintain a continuous and open dialogue with the market by way of meetings or public hearings. This will allow both the ESAs to have a better understanding of the actual market functioning and reality and market participants to be better prepared for implementation. • Direct requests for information by the ESAs should be rejected. In general, we consider that there is a need to reduce as much as possible ad hoc requests, especially if the same information has already been produced for reporting purposes and are available at the level of national authorities. There is already extensive reporting from banking institutions, both for regulatory and non-regulatory purposes, to ECB and other NCAs. Frequent data requests are operationally burdensome to manage with no obvious added value for financial stability. The penalisation for careless mistakes against such requests is not only disproportionate, but there is also the latent danger that the actually directly subordinate information requirements will in practice become a regulatory system and dilute the responsibilities of national supervision in this regard. • We believe that the actual BoS is the adequate decision-making body, since the presence of NCAs ensures that both the EU view and national specificities are taken into consideration. It is worth noting that the governing structure of the SSM has been successfully established along this same pattern. • The EACB is against this fee financing proposal and in favor of maintaining the existing simple and clear financing model (60% national supervisory authorities, 40% EU budget). This is the only way to avoid significant budget expansions of the ESAs that would be expected if funded by financial institutions. Further to that, we see there a real risk that small and medium-sized institutions be pushed out of the market, thus fostering further concentration and reduction of diversity in the banking sector.
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

4 Oct 2016 · Review of Basel 3, CRR review, Leverage ratio, EDIS

Meeting with Jonathan Hill (Commissioner)

21 Jun 2016 · SMEs, Proportionality, Basel, MREL and TLAC, EDIS, PRIIPs

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

7 May 2015 · Markets in Financial Instruments Directive II/Basel

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

14 Jan 2015 · Introductory Meeting