Intesa Sanpaolo

Intesa Sanpaolo is a major European bank and Italy's leader in retail and corporate services.

Lobbying Activity

Intesa Sanpaolo seeks EU-level coordination and quantum chip independence

12 Dec 2025
Message — The group requests a clear migration timeline for post-quantum cybersecurity and EU-wide standards for software supply chains. They emphasize the need for European independence in quantum chip production with remote access for industry players. Furthermore, they advocate for centralized EU monitoring of these actions rather than national-level oversight.123
Why — EU-based hardware would provide the bank with reliable access to high-performance processing capabilities for quantum algorithms.45
Impact — National authorities would see their influence diminished as oversight moves to a centralized European coordination model.6

Meeting with Jens Geier (Member of the European Parliament)

22 Oct 2025 · Exchange on Study for Financing on Energy Projects

Intesa Sanpaolo urges EU to streamline fragmented digital regulations

14 Oct 2025
Message — The bank requests clearer definitions for personal data, AI systems, and incidents; unified reporting through single channels; and stronger contractual protections against big tech's standard terms. They seek coordination between GDPR and AI Act requirements, plus centralized EU supervisory architecture to reduce overlapping compliance obligations.123
Why — This would reduce compliance costs and free resources currently diverted to navigating inconsistent regulations.45

Meeting with Vincenzo Matano (Cabinet of Executive Vice-President Raffaele Fitto) and FERROVIE DELLO STATO ITALIANE S.p.A. and

14 Oct 2025 · Presentation of Consumers’ Forum and exchange of views on upcoming initiatives on consumer protection

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

14 Oct 2025 · Prudential treatment of banks’ exposures to crypto-assets

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

8 Oct 2025 · Banking issues

Meeting with Irene Tinagli (Member of the European Parliament, Committee chair)

30 Sept 2025 · Meeting on housing issues

Meeting with Jens Geier (Member of the European Parliament)

16 Sept 2025 · Exchange on Financing of Energy Projects

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

4 Jul 2025 · Payments

Meeting with Fernando Navarrete Rojas (Member of the European Parliament, Rapporteur)

3 Jul 2025 · Euro Digital

Meeting with Rasmus Nordqvist (Member of the European Parliament) and Bpifrance and

25 Jun 2025 · Closed roundtable on financing the circular economy

Meeting with Brando Benifei (Member of the European Parliament)

13 Jun 2025 · Omnibus package in JURI (CSRD and CSDDD)

Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet

12 Jun 2025

Being a banking-sector stakeholder involved in regulated digitalisation projects, we believe the European Business Wallet initiative represents a strategic step towards building a common, trustworthy and simplified infrastructure for European SMEs, in the relationship with public administration and regulated private-sector entities. However, from our experience, we would like to highlight some considerations that need to be addressed. In the file attached, we provide our preliminary views that could be complemented and/or potentially revised when more details will be available on such a proposal.
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Intesa Sanpaolo calls for sustainable AI research strategy

5 Jun 2025
Message — The organization requests AI strategy focus on sustainability, supporting green and digital transitions. They call for investment in synthetic data generation, privacy-preserving AI techniques, and multidisciplinary research teams. They seek stronger support for European startups with easier seed funding access.123
Why — This would position them to leverage AI for sustainable finance research.45

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

26 May 2025 · SIU - Targeted Consultation on capital market integration

Meeting with Annalisa Corrado (Member of the European Parliament)

9 May 2025 · Taxonomy

Intesa Sanpaolo Urges Simpler EU Green Asset Ratio Reporting

26 Mar 2025
Message — The bank requests simplifying reporting templates and permanently removing complex trading book indicators. They also argue that green loan status should not require annual re-verification.123
Why — Streamlining these requirements would significantly lower the bank's operational costs and administrative workload.45
Impact — Inconsistent reporting methodologies could harm investors by reducing the comparability of sustainability data.6

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

Startup Ecosystems Development in EU Summary Startups developing Innovative and Deep Tech Enterprises (startups and SMEs) compete for the adoption of their technology across global markets but develop the technology using their local resources. Top startup ecosystems thrive not just from smart founders and active VCs, but from a deep local pool of startup-experienced world class service providers and professionals with full-lifecycle startup experiences. Without a local pool of experienced legal, financial, HR, and marketing professionals with specific experience in startup needs, the tech may be good, but the ecosystem remains stuck in a cycle of amateurs helping amateurs to be better amateurs. Currently, most of the innovation resources deployed to Emerging Startup Ecosystems for Innovation Ecosystem Development are focused only on the technical entrepreneurial founders. However, the actual gaps in the technology capabilities between Startup Ecosystems are relatively small. The larger gaps between ecosystems are in the: 1. full-lifecycle experience of the VCs; 2. startup-specific skills of the local professional service providers (Design, Legal, Marketing, Accounting, & HR) of the emerging Startup Ecosystem. Please see the attched file to have more details on our proposals.
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Meeting with Brando Benifei (Member of the European Parliament)

17 Mar 2025 · Implementation IA Act

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

12 Mar 2025 · The EU and global economic outlook

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Deutsche Bank AG and

12 Mar 2025 · Meeting of the South America Critical Raw Materials (CRM) Coalition of the Willing – Dialogue with private and public sector stakeholders, and financial institutions on sustainable critical raw materials value chains in Latin America.

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

12 Mar 2025 · Financial services policy

Intesa Sanpaolo urges permanent lower capital charges for repos

10 Mar 2025
Message — Intesa Sanpaolo supports making the current 0% and 5% funding factors for short-term reverse repos permanent. They emphasize that these transactions are vital for bond market functioning and collateral movement.12
Why — The bank would avoid new regulatory costs and a potential 2-3% drop in its liquidity ratio.34
Impact — European governments would face higher debt costs and less efficient sovereign bond markets.5

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

7 Mar 2025 · EU Omnibus

Meeting with Luděk Niedermayer (Member of the European Parliament, Rapporteur) and Deutsche Bank AG and

22 Nov 2024 · CMDI package

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur) and Deutsche Bank AG and BNP PARIBAS

21 Nov 2024 · CMDI

Meeting with Irene Tinagli (Member of the European Parliament, Rapporteur) and Deutsche Bank AG and

19 Nov 2024 · Meeting on banking issues

Meeting with Pasquale Tridico (Member of the European Parliament)

14 Nov 2024 · Meeting Online with Intesa San Paolo - euro digitale

Meeting with Nikos Papandreou (Member of the European Parliament, Shadow rapporteur)

13 Nov 2024 · Digital Euro

Meeting with Giorgio Gori (Member of the European Parliament)

6 Nov 2024 · Presentation of priorities

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

6 Nov 2024 · Digital euro

Meeting with Elena Donazzan (Member of the European Parliament)

2 Oct 2024 · Scambio di vedute sul mandato del Parlamento Europeo

Meeting with Marco Falcone (Member of the European Parliament)

2 Oct 2024 · Presentazione della struttura di European Regulatory and Public Affairs della Direzione Institutional Affairs di Intesa San Paolo

Meeting with Pasquale Tridico (Member of the European Parliament)

2 Oct 2024 · Meeting with Intesa San Paolo

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

29 Jul 2024 · Digital Euro

Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

24 Jul 2024

In case an European financial entity, such as a bank, should also issue a service as a qualified trust service provider (both roles covered by the same legal entity), should this financial entity also apply the NIS 2 (draft) implementing act, currently under consultation, to those services? Alternatively, will the DORA, as lex specialis for financial entities, be applicable to those financial entities? On the security and resilience measures included in the annex of the text under consultation, we believe that as a financial entity and as a QTSP, an entity should consider the DORA and apply also its requirements to the trust services. On the other hand, with regard to incidents, in our view the entity should refer to the specific drivers provided for the trust services as included in the draft text under consultation.
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Meeting with Isabella Tovaglieri (Member of the European Parliament)

18 Jun 2024 · Future of European banking sector

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

13 May 2024 · Basel III

Meeting with Isabella Tovaglieri (Member of the European Parliament, Shadow rapporteur)

19 Mar 2024 · EPBD

Meeting with Nicolas Schmit (Commissioner) and

6 Mar 2024 · Labour and skills shortages, the EU's social targets, the European Pillar of Social Rights Action Plan

Meeting with Marco Zanni (Member of the European Parliament)

4 Mar 2024 · EU Affairs

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

17 Jan 2024 · Macro-economic situation, Banking sector

Intesa Sanpaolo urges removal of redundant subsidiary reporting rules

24 Nov 2023
Message — The bank requests the deletion of rules requiring listed subsidiaries to file separate sustainability reports. They argue these companies should be exempt if covered by group-level reporting.12
Why — Centralizing reporting would reduce the bank's administrative overhead and technical infrastructure costs.34
Impact — Financial stakeholders lose specific transparency regarding the ESG performance of individual listed subsidiaries.5

Meeting with Alfred Sant (Member of the European Parliament, Rapporteur)

10 May 2023 · Listing Act

Response to Interim Evaluation of the InvestEU Programme

8 May 2023

Intesa Sanpaolo is the leading Italian bank in all markets segments and among the largest Eurozone banking groups by market capitalisation. In this capacity Intesa Sanpaolo can play a fundamental role in achieving European objectives and implementing EU policies. In fact, Intesa Sanpaolo is currently active as financial intermediary (through the EIF) under the InvestEU program, as it was with EFSI in the previous MFF. Attached you can find a position paper detailing our feedback to the InvestEU program, mainly related to the amount of resources obtained following our expression of interest, operational aspects and overall consistency of the EU objectives pursued by InvestEU. We stand ready for any clarification you might need.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

27 Apr 2023 · Transition to a circular economy, the role of the banking sector and the actions of Intesa Sanpaolo

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

27 Apr 2023 · Transition to a circular economy, the role of the banking sector and the actions of Intesa Sanpaolo

Meeting with Liviu Stirbat (Cabinet of Executive Vice-President Margrethe Vestager)

27 Apr 2023 · Transition to a circular economy, the role of the banking sector and the actions of Intesa Sanpaolo. Meeting organized by Cab Timmermans.

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

27 Apr 2023 · Transition to a circular economy, the role of the banking sector and the actions of Intesa Sanpaolo

Meeting with Santina Bertulessi (Cabinet of Commissioner Nicolas Schmit)

22 Mar 2023 · Gender, diversity and inclusion policies in the EU

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

8 Mar 2023 · Corporate Sustainability Due Diligence

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

8 Mar 2023 · Italian macro- economic situation, the impact of the Russian war on growth and on the EU banking sector, the EU response to the current crisis

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

7 Mar 2023 · IT macro-economic situation, impact of war in Ukraine anf the EU banking sector

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

21 Feb 2023 · Retail Investment Strategy

Meeting with Irene Tinagli (Member of the European Parliament, Committee chair) and BNP PARIBAS

16 Jan 2023 · Meeting on Banking Issues

Response to Instant Payments

29 Dec 2022

Intesa Sanpaolo, one of the top banking groups in the European Union, welcomes the opportunity to provide preliminary feed-back to the co-legislators about the European Commissions proposal for an Instant Payment Regulation. As highlighted in other European Commissions public consultations, Intesa Sanpaolo fully supports the development of Instant Payments (IPs) across EU countries. We shared the European Commissions concerns on the still low level of adherence to the SCT Inst scheme by EU PSPs and urged the Commission to act and take most effective measures to make IP available to every European citizen across the EU by establishing a reachability obligation for EU PSPs under the SCT Inst. Scheme. IPs are, for Intesa Sanpaolo, a key driver for innovation in digital payments. This is the reason why the Group was one of the very first banks to adhere to the voluntary SCT Inst scheme back in November 2017, thus allowing its customers to be among the first in the EU being able to make and receive payments in real-time. While praising the Commission for having acted on this matter, we would also like to express our concerns about some measures of the current proposal as they are, in our opinion, disproportioned compared to the goals the proposal itself aims to achieve. We understand that the Commission intention is to develop a pan-European payment solution based on IPs, as it is a high-priority objective in the EU policy agenda. However, even though we agree that IPs could be a valuable tool in reaching this goal, it is equally true that IPs alone cannot be the silver bullet. IPs are just a way to transfer funds account to account to be used for specific use cases when such a service level is required and are not a payment network. We see a risk of a very low uptake of IPs by EU consumers, if the same experience offered by cards and other alternative payments methods wouldnt be met (e.g. customer protection, unique experience for payment initiation, adequate branding awareness, merchant services).In other words, we consider that the current proposal is disproportioned in terms of efforts required to PSPs and, even if implemented as it is, it will not be able to fully achieve the objectives it intends to reach. Please, find attached our key considerations and suggested amendments to the proposal.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

15 Nov 2022 · Energy infrastructure investments; hydrogen

Response to Review of EU rules on payment services

1 Aug 2022

Intesa Sanpaolo, one of the top banking groups in Europe, welcomes the opportunity to participate to the debate on the Second Payment Services Directive (PSD2) review, and would like to contribute to the European Commission’s call for evidence on the matter. Overall, we believe the PSD2 has positively contributed to both the development of new technological solutions and the increasing of safety in the payments market, even though it is fair noting that the level playing field principle has not always been ensured and the implementation phase has been complex, long-lasting and costly. Since the PSD2’s publication, in 2015, we are witnessing new technological developments and several lessons can be learnt from its implementation. Even though we believe the overall PSD2 framework remains “fit for purpose” and” future proof”, these aspects need to be carefully considered and properly addressed during the review. Therefore, Intesa Sanpaolo welcomes this exercise, as it is very timely and appropriate. Considering the above, we would like to suggest limited and targeted amendments on the following aspects, in case of a revision of the PSD2: • Scope • Definitions • Security aspects • Liability aspects • Transparency • Interaction between level 1 and level 2 legislation • Regulatory alignment & level playing field Please, find more information in the file attached. Please, also note that we complement our response with further comments from a cybersecurity perspective.
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Response to Distance Marketing of Consumer Financial Services - Review of EU rules

7 Jul 2022

Intesa Sanpaolo thanks the European Commission for the opportunity to comment on the proposed reform of the EU legislation on the distance marketing of consumer financial services. Here below our three main comments, regarding the scope, pre-contractual information and subsequent transactions. First, it is necessary to clarify the actual scope of the directive, in particular with reference to the closing rules on pre-contractual information (Art. 16 bis, par. 6), withdrawal (Art. 16 ter, par. 6) and adequate explanations (Art. 16 quinquies, par. 4) where they are already regulated by specific sector directives (i.e CCD, PSD2, MiFID II, PAD, IDD). In fact, on pre-contractual information, it’s necessary to clarify whether the aforementioned directives allow for a total non-application of the above mentioned articles of Directive 2011/83, or whether there is the need to integrate the specific aspects not currently regulated in the sector legislations (e.g. MiFID II and IDD do not provide for the information relating to phone number and electronic address; as set forth in Art. 39 of PSD2 a list of DMFSD’s articles shall be disapplied). A total non-application is for instance recommended by ESMA and EIOPA with specific reference to the pre-contractual information. The ESAs in their reports on investor protection in order to rationalize the information required by the various legislations (MIFID II, IDD, Solvency, DMSFD) suggest the non-application of the rules relating to pre-contractual information regulated by the DMSFD, considering the latter's information substantially a duplication of the information already provided in the MIFID II and IDD framework. We support ESMA and EIOPA suggestion. Clarity on this point also would allow national legislation to disapply the rules set out in Directive 2002/65/EC for bank and payment products, thus avoiding unnecessary burden on banks. Furthermore, in the context of MiFID II, some provisions on pre-contractual disclosures are contained in the ESMA Guidelines on certain aspects of the MIFID II suitability requirements. It would therefore be essential to clarify whether the guidelines of the ESAs are also included among "other Union acts". Thus, for example, with regard to the request for human intervention, for which the ESMA GL only require information to be given about "if and how the client can ask for human interaction", therefore not granting the customer a right to obtain human intervention, as would be the case under Art. 16 quinquies par. 3 of the proposal. As a second point, with reference to the obligation to deliver pre-contractual information at least 1 day before the conclusion of the contract, the PSD2, PAD, CCD, MiFID II and IDD sector legislations apply the concept of "good time". In our view, the obligation to deliver 1 day before the conclusion of the contract could negatively affect the interests of the customer (e.g. a transaction involving products subject to price fluctuation to be implemented 1 day after the request would entail for the customer the risk of a negative price change). In addition, such obligation may also not be consistent with the typical characteristics of distance marketing of financial services, which entail a swift execution. Therefore, the pre-contractual information should instead be provided "in good time" or "before the conclusion of the contract”. Alternatively, the reference to "exceptional cases" should be deleted from recital 17 and, as a consequence, sending a reminder to the client on the right of withdrawal for any financial product should become the ordinary alternative. Finally, in recital 15 about the distinction between subsequent transactions and additional contracts, it is necessary to clarify whether there is also a relationship with post-sale activities (e.g. additional payments/switches) to be considered as subsequent transactions and not as additional contracts.
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Meeting with Santina Bertulessi (Cabinet of Commissioner Nicolas Schmit)

29 Jun 2022 · Social economy

Meeting with Marco Zanni (Member of the European Parliament, Shadow rapporteur)

31 May 2022 · AMLD Review

Italian banking giant seeks clarity on EU sustainability due diligence rules

23 May 2022
Message — The bank requests clearer definitions of key terms, confirmation that due diligence applies only to new client onboarding, and explicit exclusion of all SMEs from financial firms' value chain obligations. They warn that contractual assurances throughout the value chain will create heavy operational burdens and litigation risks.12345
Why — This would reduce compliance costs and operational complexity while protecting existing client relationships from disruption.678

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

29 Apr 2022 · Impact of the war on IT economy, gas imports and consumption in IT, fiscal policy and the RRP, overview of the banking sector

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

27 Apr 2022 · EU banking

Meeting with Brando Benifei (Member of the European Parliament, Rapporteur)

12 Jan 2022 · Discussion on the eu commission's initiative "Have your stay"

Meeting with Salvatore De Meo (Member of the European Parliament)

12 Jan 2022 · Direttiva Credito ai Consumatori

Meeting with Gert Jan Koopman (Director-General Budget)

12 Oct 2021 · EU Primary Dealer Network

Intesa Sanpaolo urges exemptions and clarity for banking AI regulation

30 Jul 2021
Message — The bank requests clearer integration with banking rules, exemptions for non-credit AI uses, and elimination of statistical approaches from the AI definition. They argue current requirements are technically impractical and excessively burdensome.123
Why — This would reduce compliance costs and avoid applying disruptive credit-lending rules to other banking operations.45
Impact — Consumer protection weakens if banking AI systems face fewer bias-detection and transparency requirements.67

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

25 May 2021 · analysis of Italian economy

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

17 May 2021 · EU economy in the recovery phase

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association for Financial Markets in Europe and

27 Apr 2021 · Sustainable Finance

Meeting with Mattia De' Grassi (Cabinet of Vice-President Dubravka Šuica)

9 Apr 2021 · Discussion on the Conference on the Future of Europe

Response to An act specifying when commercial terms of central clearing are fair, reasonable, non-discriminatory and transparent

1 Apr 2021

We are pleased to reply to this consultation and would like to draw EC attention on specific issues extremely critical for us. A.Delegated Regulation (DR) Implementation period (Art.3): 1) We are pleased to notice that EC acknowledges (Recital 8) the need to give clearing service providers (CSPs) sufficient time to prepare for application of DR and, thus, to defer its application. That said, we fear that a 3-month period after entry into force for the DR to apply is insufficient. We deem necessary that the DR applies 9 months after its entry into force and, in any case, no less than 6 months. 2) The length of the implementation period is strictly linked to the issue of the clients’ scope: in case RTS apply also to existing clients, CSPs should be given more time to implement RTS. 3) We welcome that EC acknowledges (Recital 8) that DR should enter into force as a matter of urgency. Thus, we believe necessary that DR is adopted at the earliest possible opportunity after this consultation and not later than April to give CSPs and their clients legal certainty and guidance with due advance. Scope (Art.2): 1) As a starting point, we would like to underline that, with the existing clients, a “pre-FRANDT” negotiating phase has already occurred. 2) We invite EC to clarify, in the final version of DR, whether RTS apply only to prospective clients of CSPs or also to those existing when DR is adopted. 3) The application of RTS to existing clients may imply the need to review previously contracted commercial terms, in particular fees, prices and discounts. On its turn, this review could trigger a re-negotiation potentially leading to higher/lower final costs for these clients, as the case may be. Thus, should EC clarify that RTS apply also to existing clients, we also invite EC to clarify i) whether such re-negotiation must be carried out in both cases mentioned above and ii) by which deadlines. 4) Last but not least, we would like to draw EC attention on the fact that applying RTS to existing clients risks being extremely burdensome and costly, both from a commercial point of view and in terms of relationships, for all clearing members when it comes to managing fee schedules. B.Annex Transparency of the on-boarding process: 1) In the Explanatory Memorandum (EM), EC deems ESMA 3-step onboarding process overly prescriptive. In light of EM and point 1 of Annex, we invite EC to confirm that there is no obligation for prospective clients to send RFP (the one available on clearing members website or any other form) i.e. that the choice to be made relates to sending or not RFP as such and not to which specific RFP model to send. 2) Seemingly, ESMA and EC have adopted a different approach, in terms of granularity, on transparency and this could be concerning. In particular, we invite EC i) to consider that achieving an acceptable degree of transparency in relation to commercial terms is likely to increase operational complexities and related costs and, therefore, ii) to strike a proper balance between these two aspects when drafting the final version of the Annex. 3) Moreover, another key concern raised by EC proposals regarding transparency relates to level playing field: in this respect, we invite EC to consider, when drafting the final version of the Annex, that a good level of transparency requires clear standards to be adopted by all market participants in order to avoid lack of competition and comparability across pricing. Fees and pass-on costs: We invite EC to confirm that “fees and pass-on costs, as agreed between the CSP and the client” (point 6.3.) are to be construed as those included in the proposal as per point 3 of Annex i.e. that the fees and pass-on costs included in this latter proposal may not be subsequently re-negotiated by parties. Notice period: The 6-month period does not raise major concerns provided that exception to this rule is allowed to make immediate solutions feasible where necessary
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Response to Central securities depositories – review of EU rules

1 Apr 2021

We are pleased to provide our comments on the CSDR roadmap and would take this opportunity to draw EC attention on four specific issues extremely critical for us. For more details on our stance on the CSDR review as a whole (including internalized settlement and scope) please see our response to the recent targeted consultation. Rules on buy-in (BI): we have particularly appreciated EC decision to include BI among the topics of consultation document and to hear market participants’ views on that. In line with our response, we believe the upcoming EC legislative proposal on CSDR review should give utmost priority to amend many and relevant aspects of BI regime. First, we deem necessary that BI turns from mandatory obligation into optional right in relation to non-cleared transactions. Other key proposals from our side are: a pass-on mechanism, greater flexibility in appointing buy-in agents, symmetrical and bidirectional flows of differential payments, application of BI i) only where settlement instructions represent an underlying contractual agreement between buyer and seller to sell securities against an agreed price and ii) only to trading parties (for non-CCP cleared transactions). Rules on penalties: the CSDR penalty regime is overall adequate. The only amendment we would deem necessary is the i) removal of CCPs responsibility (Art. 19 RTS) to collect and distribute penalties to clearing members affected by settlement fails and ii) centralization on CSDs of this responsibility for CCP-cleared and bilateral transactions. Timing concerns: as of now, we are engaged and determined to i) meet the deadline prescribed by rules currently in force and ii) achieve the goal of full and timely compliance with settlement discipline regime (SDR) due to go live in 1.2.22. Major implementation efforts are under way and substantial resources are being deployed so as to attain this deadline/goal. That said, we have two main concerns associated with timing. First, as of now i.e. at short distance before the EC presents the legislative proposal on CSDR review (scheduled in Q4 2021 as per the roadmap) it is not clear i) which areas of CSDR will be covered by the proposal ii) whether SDR will be addressed by it and iii) if so, which peculiar aspects of SDR will be reviewed. Second, the risk is real that an “old” legislative framework will have to be implemented while a legislative process for amending would have already started at that time. These concerns are even more compelling due to the flaws of BI regime and the need to amend it before implemented as indicated above. Next steps: we invite the EC i) to provide at the earliest possible opportunity and in any case not later than end of April a clear indication regarding a) the scope of CSDR review legislative proposal and b) the timeline of implementation of SDR and, in this context, ii) to clarify and to plan/take concrete steps so as that a) the implementation of BI regime will be postponed until amendments thereto are approved and b) the date of implementation of the amended BI regime will be decoupled from the date of implementation of other aspects of the SDR. This two-phased approach to implementation timing of SDR would have two merits. First, postponing implementation of BI regime would not prevent other parts of SDR from being implemented as per current legislative schedule: this is the case, for example, of the penalty regime which is overall adequate and does not need, as of now, major amendments, apart the one mentioned above. Second, market participants a) would be provided with additional time to plan and implement necessary activities to adapt themselves to the amendments to BI regime (e.g. changes to IT systems/technologies, contractual adjustments and related counterparties’ outreach etc.) and b) would not incur the risk that their activities and related investments are made redundant or, even worse, need to “restart from zero”.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and Association for Financial Markets in Europe and

16 Mar 2021 · Sustainable finance, Green recovery

Response to Enhancing the convergence of insolvency laws

9 Dec 2020

Intesa Sanpaolo strongly welcomes the Inception Impact Assessment (IIA) of the European Commission (EC) on benchmarking and harmonizing national insolvency procedures in the EU. We also share the general goals and principles announced by the EC, in particular with regard to: (i) Fostering cross border investments, also in light of the need to accomplish the Capital Markets Union (ii) Strike a balance between the interests of the different economic actors, while pursuing more predictable insolvency frameworks and ultimately enhance economic growth. We support the general objective of achieving a greater degree of harmonization in some specific areas, and for this reason we believe that the initiative should consist of a Directive, expect for those needs mentioned below. Such legislative solution should allow for a higher degree of minimum standards across Member States, provide for a clear timeline and avoid the uncertainties and discrepancies linked to simple guidelines or recommendations which would be implemented in different ways across Member States. We also share many of the specific objectives highlighted in Section B of the IIA (with the exception of protection of secured creditors). In addition, we would investigate and support also legislative actions for: - the possibility to exempt from criminal liability risks financial creditors supporting corporates under distress / insolvency in specific restructuring proceedings. Such exemption would be beneficial in so far it would not disincentivize creditors or investors from attempting the rescue of distressed companies. - The harmonization of the conditions and consequences as regards the claims for revocation. In particular it would be extremely useful to define (i) common triggers for such actions to be initiated and (ii) the duration of their effects vis-à-vis creditors. We refer in particular to the definition of the terms for forfeiture and statute of limitation to exercise the claims for revocation. A harmonization of such terms would ensure a consistent framework and facilitate cross border transactions, for instance with regard to the treatment of guarantees received by the creditors. Such legislative interventions would facilitate the intervention of a greater number of financial actors in the context of corporate restructuring, therefore facilitating bridge financing and other financial structures to the benefit of corporates’ recovery. Moreover, a Directive could also allow to meet objective (v), i.e. foster court capacity, expertise and training of judges. Finally, it is worth underlying that, as noted above, for specific needs - such as, for instance, the protection of secured creditors in insolvency - a harmonization is not feasible as national laws and preferences differ widely.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

4 Nov 2020 · Latest macroeconomic developments and NPLs

Response to Review of the Benchmark Regulation

6 Oct 2020

Intesa Sanpaolo welcomes the initiative of the European Commission (EC) to undertake a review of the Benchmark regulation (BMR) and the opportunity to comment on the Proposal published on 24 July. The European Commission correctly identifies the crucial issue that needs to be addressed by the Proposal: to ensure a smooth transition away from a critical benchmark in cessation and face the risk of frustrating a broad stock of legacy contracts whose renegotiation proved impossible. From our perspective, the solution advanced by the EC’s Proposal of introducing new statutory powers - which enable the EC to impose a replacement rate for a critical benchmark in cessation - is the right one and it is in line with what Intesa Sanpaolo suggested in its feedback to the EC’s Inception Impact assessment back in April 2020. The aim of the comments contained in the attached document is to highlight some aspects of the Proposal which may create uncertainty and inconsistencies with respect to its application, as firms are planning their ways and strategies with respect to the so-called tough legacy contracts.
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Meeting with Alessio Nardi (Cabinet of Commissioner Olivér Várhelyi) and Philip Morris International Inc. and

11 Sept 2020 · Breakfast with institutional and economic stakeholders organised by Rep and Comin & partners

Response to Review of the Benchmark Regulation

15 Apr 2020

Intesa Sanpaolo welcomes the initiative of the European Commission to undertake a review of the Benchmark regulation (BMR) and the opportunity to comment on the inception impact assessment. The European Commission correctly identifies in the inception impact assessment the crucial issues that need to be addressed by a review of the BMR. From our perspective, addressing the issues related to the transition to risk free rates, notably the stock of legacy contracts and the identification of the alternative fallback rates, is crucial and rightly deserves a targeted legislative measure at the European level. Fallback rates As regards the issue of the identification of the alternative fallback rate, Intesa Sanpaolo believes that a statutory solution at the European level – taken either through a European Commission’s Delegated Act or by a decision of the European Securities and Markets Authority – would avoid the fragmentation risks linked to inconsistent implementation by Member States. Furthermore, the European Commission should in its review of the regulation pay particular attention to the consequences arising from different fallback rules applied to different instruments (e.g cash and derivatives products). A clear rule for different products and different currencies – by adopting criteria related to volumes and/or complexity of products and/or difficulties to amend the contracts in any single country – could avoid new basis risk, potential market disruption and mitigate the impact on hedge accounting. Finally, Intesa Sanpaolo considers that each single benchmark administrator should be obliged to publish the fallback for its own benchmark, with at least a two level waterfall, thus allowing all counterparties to make reference to a standard and official rule (validated if possible by the national authority that supervise the administrator), instead of obliging any single entity to decide on different fallback conditions. Communication and transparency Intesa Sanpaolo considers that the review of the BMR could also be the opportunity to foster a harmonized approach at European level on communication and transparency issues related to the transition to risk-free rates. It would be really useful, for example, to have a common and clear approach involving subjects identified ex-ante (at the institutional level if possible) and tasked with all activities related to communication. This would help in reaching all national associations and financial institutions, without leaving to the single bank, designed as Ambassador, the responsibility to spread the information within its jurisdiction. Mandatory register Finally, the review of the BMR could also be the time to simplify the mandatory registers that each counterparty is obliged to maintain. Ideally, a complete list of all benchmarks could be managed by an international entity and for each single benchmark standard fallback rules would be in place. Each single bank would flag the benchmarks in use on a shared platform and would be compliant with the regulation only by adding, if necessary, additional reference to specific procedures or other internal requirements. The regulators will have a real-time view of the most used benchmarks and the banks will avoid any time-consuming activity. Intesa Sanpaolo is keen to continue the dialogue with the European Commission and ESMA on these and other technical improvements to the Benchmarks Regulation and looks forward to the upcoming proposals.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

19 Feb 2020 · Payments

Response to Gender equality in the EU

13 Feb 2020

Please see the attached file
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

28 Jan 2020 · European and Italian macro-economic situation

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis), Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and

11 Oct 2019 · Instant payments

Meeting with Marion Perelle (Cabinet of Vice-President Miguel Arias Cañete)

28 May 2019 · Report on Mediterranean and Italian Energy

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

14 May 2019 · SME access to finance, sustainable finance, Fintech

Meeting with Jyrki Katainen (Vice-President)

16 Nov 2018 · Intesa Sanpaolo latest results and business strategy.

Meeting with Valdis Dombrovskis (Vice-President) and

15 Nov 2018 · Italian banking system - Intesa Sanpaolo, Non-performing loans package, Banking package

Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

11 Oct 2018 · Transport study

Response to Safekeeping duties of depositaries for UCITS funds

25 Jun 2018

With reference to the consultation, Intesa Sanpaolo SpA acts as a delegated sub custodian for a number of depositaries acting on behalf of AIF and UCIT clients. We welcome the opportunity to comment on the draft legislation as it will allow for clarity in particular for the parts which may impact our carrying out of our responsibilities and services as a delegated sub custodian under the mandates stipulated with our depositary clientele both from an operational and contractual perspective. In general, we favour the segregated omnibus structure dedicated to the commingled asset holdings of AIF and UCIT clients as it fosters efficiency and automation in trade processing. In particular, with the aim of structuring a clear minimum service standard as a sub custodian, we suggest the following: A minimum frequency be defined for the providing of information for the reconciliation activities to be performed. This would allow clarity for the same processes to be contractually stipulated if the delegated parties use other third parties down the custody chain in accessing different markets. In terms of due diligence and oversight we fully understand the necessity of the depository to monitor the delegated third party. We however suggest that the statement to be obtained confirming the correct handling of the assets attests that there have been no “material” change (as opposed to “change”) affecting how the assets are held in accordance to the contractually stipulated arrangements in place. Furthermore, as to the necessity of providing an independent legal opinion assessing the solvency of the third party where the depositary has delegated the custody function, we suggest that this requirement be clarified so that it is clear that the opinion be limited to country of the delegated third party of the depositary (as opposed to also include additional opinions for other jurisdictions where the delegated third party may have appointed other third parties in the custody chain).
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Response to Safekeeping duties of depositaries for Alternative Investment Funds

25 Jun 2018

With reference to the consultation, Intesa Sanpaolo SpA acts as an delegated sub custodian for a number of depositaries acting on behalf of AIF and UCIT clients. We welcome the opportunity to comment on the draft legislation as it will allow for clarity in particular for the parts which may impact our carrying out of our responsibilities and services as a delegated sub custodian under the mandates stipulated with our depositary clientele both from an operational and contractual perspective. In general, we favour the segregated omnibus structure dedicated to the commingled asset holdings of AIF and UCIT clients as it fosters efficiency and automation in trade processing. In particular, with the aim of structuring a clear minimum service standard as a sub custodian, we suggest the following: A minimum frequency be defined for the providing of information for the reconciliation activities to be performed. This would allow clarity for the same processes to be contractually stipulated if the delegated parties uses other third parties down the custody chain in accessing different markets. In terms of due diligence and oversight we fully understand the necessity of the depository to monitor the delegated third party. We however suggest that the statement to be obtained confirming the correct handling of the assets attests that there have been no “material” change (as opposed to “change”) affecting how the assets are held in accordance to the contractually stipulated arrangements in place. Furthermore as to the necessity of providing an independent legal opinion assessing the solvency of the third party where the depositary has delegated the custody function, we suggest that this requirement be clarified so that it is clear that the opinion be limited to country of the delegated third party of the depositary (as opposed to also include additional opinions for other jurisdictions where the delegated third party may have appointed other third parties in the custody chain).
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Response to Development of secondary markets for non-performing loans

8 Jun 2018

Intesa Sanpaolo supports the Commission’s proposal which aims at boosting NPL secondary markets and at increasing protection of secured creditors from business borrowers’ default. However, a number of issues in the proposed Directive are still unaddressed and remain a source of concern for Intesa Sanpaolo along with other market participants. Please refer to the attached document for our key messages and detailed comments.
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Association for Financial Markets in Europe and

6 Jun 2018 · Cyber security, Fintech

Intesa Sanpaolo urges flexible provisioning for non-performing loans

25 May 2018
Message — The bank requests flexible provisioning rules instead of automatic backstops. They suggest extending the time-window for unsecured loans and excluding forborne exposures.123
Why — Increased flexibility would allow the bank to avoid costly capital deductions and burdensome implementation.45
Impact — Small businesses and households would suffer from higher interest rates and restricted access to credit.6

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

22 May 2018 · italian Macro-economic situation

Response to Initiative on an integrated covered bond framework

9 May 2018

Intesa Sanpaolo supports the set-up of a single and holistic European framework for the Covered Bonds as a building step of the Capital Markets Union. Covered Bonds have gained in the last ten years a leading role throughout the EU as a secured funding channel, showing a remarkable resilience even during the most severe phase of the financial crisis. According to Intesa Sanpaolo, a limited number of provisions of the current regulatory draft could trigger unwarranted discriminatory effects in certain jurisdictions and on SPV-based Covered Bond structures. In particular, our concerns are on: Derivatives: hedging interest rate or currency risks should make the covered bond structure sounder. However, we fear that including the derivatives inside the cover pool may work for certain jurisdictions but may not work at all for others. Therefore, the provisions on derivatives should be improved in order to be applicable to all jurisdictions and to avoid systemic risks (by concentrating derivatives on highly rated institutions only). Liquidity Buffers: the Commission’s proposal may ultimately increase concentration of liquidity on highly rated institutions, thus discriminating sound banks established in more peripheral jurisdictions. The proposal should be calibrated in order to take into account actual risk factors and the current state of play of the market. Eligible assets: Intesa Sanpaolo believes that the Directive should aim at protecting the covered bond franchise by allowing high quality and traditional assets as collateral. This objective could also be achieved by explicitly introducing a category of new dual recourse securities backed by non-core high quality assets (SME, infrastructure, the so called European Secured Notes), thus also encouraging the financing of the real economy along with the CMU guidelines.
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Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

6 Mar 2018 · Investment in maritime & med area

Intesa Sanpaolo urges bank-specific approach for non-performing loans

7 Dec 2017
Message — Intesa Sanpaolo opposes fixed-time full provisioning and calls for bank-specific recovery measures. They suggest addressing bad loans through existing bilateral supervisory powers instead of standard rules. Forborne exposures should be explicitly excluded to mirror their flexible nature.12
Why — This would reduce compliance costs and prevent the forced sale of assets at discounted prices.34
Impact — Households and small businesses would face higher interest rates and restricted access to loans.56

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

10 Nov 2017 · European Banks; NPL

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici)

10 Nov 2017 · Addendum to the ECB Guidance to banks on non-performing loans

Meeting with Julie Ruff (Cabinet of Commissioner Julian King)

26 Oct 2017 · Cyber security

Response to DA on product oversight and governance requirements for insurance undertakings and insurance distributors

16 Aug 2017

The group welcomes the European Commission’s delegated acts concerning the Insurance Distribution Directive (IDD). In particular, we support the approach of setting as principles underpinning the advice, the principle of proportionality along with the consistency with MiFID II. These principles provide a solid and efficient framework for the implementation of the IDD. Response to the consultation: • Target market – We welcome the introduction of a principle of proportionality for the granularity of the definition of target market – considering also that some insurance product are mandatory. • Acting as a manufacturer – We welcome the definition of when distributors shall be considered as manufacturers provided in article 3. It provides clarity on the respective roles, and consequently, on the respective responsibilities. In particular, the list of practices that shall be considered / or shall not be considered “acting as a manufacturer” provided by EIOPA in its Technical advice, proves to be particularly useful to check existing practices against the new definitions. However, it seems still unclear to us the regime applicable when the distributor provides guidance to the manufacturer on the possible features of a product and the manufacturer (following an internal assessment) fully endorses the distributor’s suggestions. We would not interpret this as having a decision-making role, as the distributor is not autonomously determining the essential features and main elements of the product. However, we would welcome further clarity on this point in the delegated acts. • Information on the product from the manufacturer (art.8) – we support and encourage a continuous and fruitful flow of information between the manufacturer and the distributors, for the benefit of customers and providers alike. However, it is not clear to us how the requirement in art. 8.2 for the manufacturer to share information on the “circumstances that may cause conflict of interest to the detriment of the customer” can be applied. Notably, in light of the fact that such circumstances usually arise and are communicated to the clients during the distribution phase and may occur on a stand-alone case (i.e. not continuously). Against this background, we wonder how the requirement for a flow of information should work in practice. • Information on the product to the manufacturer (art.11) – on a similar note, we praise a higher level of proportionality in the information that distributors shall channel to manufacturers. Though, some doubts remain on how the requirement to inform the manufacturer on “circumstances that may adversely affect the customer ” can be applied for non-life insurances (i.e.property & casualty). • Methodology and criteria for a assessing detrimental impact stemming from inducement – we acknowledge the importance of preventing conflicts of interest in light of their potential detrimental impact on consumers, in line with our corporate approach of promoting the highest standards for consumer protection. Against this background, we would like to share our concerns on the requirement of art.8.2(b) of the methodology to assess detrimental impacts. Indeed, this requirement lists among the criteria, the cases when “the scheme is solely or predominantly based on quantitative commercial criteria and does not take into account appropriate qualitative criteria”. While we share the concerns that compliance with “applicable regulations, fair treatment of customers and quality of service” shall be duly assessed, we also acknowledge that quantitative criteria remain the most reliable and measurable benchmark when assessing whether to provide inducements. We think that a mix of both criteria would provide adequate protection to customers, and would also balance the subjectivity linked to qualitative criteria. In light of the above, we think that the requirement should list only when inducement is solely based on quantitative commercial criteria.
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Response to DA on conduct of business rules for the distribution of insurance-based investment products

11 Aug 2017

The group welcomes the European Commission’s delegated acts concerning the Insurance Distribution Directive (IDD). In particular, we support the approach of setting as principles underpinning the advice, the principle of proportionality along with the consistency with MiFID II. These principles provide a solid and efficient framework for the implementation of the IDD. Response to the consultation: • Target market – We welcome the introduction of a principle of proportionality for the granularity of the definition of target market – considering also that some insurance product are mandatory. • Acting as a manufacturer – We welcome the definition of when distributors shall be considered as manufacturers provided in article 3. It provides clarity on the respective roles, and consequently, on the respective responsibilities. In particular, the list of practices that shall be considered / or shall not be considered “acting as a manufacturer” provided by EIOPA in its Technical advice, proves to be particularly useful to check existing practices against the new definitions. However, it seems still unclear to us the regime applicable when the distributor provides guidance to the manufacturer on the possible features of a product and the manufacturer (following an internal assessment) fully endorses the distributor’s suggestions. We would not interpret this as having a decision-making role, as the distributor is not autonomously determining the essential features and main elements of the product. However, we would welcome further clarity on this point in the delegated acts. • Information on the product from the manufacturer (art.8) – we support and encourage a continuous and fruitful flow of information between the manufacturer and the distributors, for the benefit of customers and providers alike. However, it is not clear to us how the requirement in art. 8.2 for the manufacturer to share information on the “circumstances that may cause conflict of interest to the detriment of the customer” can be applied. Notably, in light of the fact that such circumstances usually arise and are communicated to the clients during the distribution phase and may occur on a stand-alone case (i.e. not continuously). Against this background, we wonder how the requirement for a flow of information should work in practice. • Information on the product to the manufacturer (art.11) – on a similar note, we praise a higher level of proportionality in the information that distributors shall channel to manufacturers. Though, some doubts remain on how the requirement to inform the manufacturer on “circumstances that may adversely affect the customer ” can be applied for non-life insurances (i.e.property & casualty). • Methodology and criteria for a assessing detrimental impact stemming from inducement – we acknowledge the importance of preventing conflicts of interest in light of their potential detrimental impact on consumers, in line with our corporate approach of promoting the highest standards for consumer protection. Against this background, we would like to share our concerns on the requirement of art.8.2(b) of the methodology to assess detrimental impacts. Indeed, this requirement lists among the criteria, the cases when “the scheme is solely or predominantly based on quantitative commercial criteria and does not take into account appropriate qualitative criteria”. While we share the concerns that compliance with “applicable regulations, fair treatment of customers and quality of service” shall be duly assessed, we also acknowledge that quantitative criteria remain the most reliable and measurable benchmark when assessing whether to provide inducements. We think that a mix of both criteria would provide adequate protection to customers, and would also balance the subjectivity linked to qualitative criteria. In light of the above, we think that the requirement should list only when inducement is solely based on quantitative commercial criteria.
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Commerzbank AG and

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

Meeting with Arianna Vannini (Cabinet of High Representative / Vice-President Federica Mogherini)

11 May 2017 · Banking Union

Meeting with Ingrid Bellander Todino (Cabinet of Commissioner Julian King)

31 Mar 2017 · Cybersecurity

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

16 Sept 2016 · TLAC and MREL review

Meeting with Frans Timmermans (First Vice-President) and

2 Sept 2016 · European Affairs

Meeting with Miguel Gil Tertre (Cabinet of Vice-President Jyrki Katainen)

16 Feb 2016 · EFSI

Meeting with Arianna Vannini (Cabinet of High Representative / Vice-President Federica Mogherini)

26 Jan 2016 · Banking Union

Meeting with Massimo Suardi (Cabinet of Vice-President Valdis Dombrovskis)

21 Sept 2015 · legislative initiative recently published by the Croatian Government

Meeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)

21 Sept 2015 · Financial Services Policy

Meeting with Aare Järvan (Cabinet of Vice-President Andrus Ansip)

18 Sept 2015 · Virtual currency

Meeting with Jonathan Hill (Commissioner)

22 Jul 2015 · Financial Services Policy

Meeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)

7 Jul 2015 · Financial Services Policy

Meeting with Arianna Vannini (Cabinet of High Representative / Vice-President Federica Mogherini)

11 Jun 2015 · Meeting with Intesa Sanpaolo Bank - Cortesy visit

Meeting with Massimo Suardi (Cabinet of Vice-President Valdis Dombrovskis)

10 Jun 2015 · Meeting with Intesa Sanpaolo: presentation of the activities of the International and Regulatory Affairs department of Intesa Sanpaolo, EU economic governance, general discussion

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

23 Apr 2015 · EFSI

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen) and Deutsche Bank AG and

9 Dec 2014 · Investment initiative