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The Bank of New York Mellon

BNY

BNY is a global financial services company focused on investment services and investment management.

Lobbying Activity

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

13 Jan 2026 · The proposal for a depositary passport in the context of the market integration package

Meeting with Jennifer Robertson (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

12 Jan 2026 · CSDR - SIU Proposal

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

30 Sept 2025 · Savings and Investments Union

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

30 Sept 2025 · Competitiveness and simplification in the financial sector

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

5 Jun 2025

BNY welcomes the opportunity to respond to the European Commissions call for evidence in relation to a planned legislative initiative entitled Savings and Investments Union: Fostering integration, scale and efficient supervision in the single market. BNY is a global financial services firm operating in the European Union (EU) primarily through a European bank headquartered in Belgium with branches in nine EU member states. BNY is fully supportive of the objective of building a Savings and Investments Union (SIU), and of initiatives to tackle the problems of (i) barriers that fragment the EU market infrastructure, (ii) barriers to the operations of asset managers and distribution of funds, and (iii) fragmented supervision. BNY believes that the current fragmentation in the European Union post-trade landscape is one of key reasons why European capital markets are themselves fragmented and too small. One critical requirement for tackling the fragmentation in the post-trade landscape is that all entities providing the three core CSD services under CSDR (issuance of securities for issuers, central maintenance of securities accounts for investors, and provision of a settlement system for trading parties) should provide these services in a very highly standardised manner. With respect to the barriers to the operations of asset managers and distribution of funds, we would highlight the benefits of a legislative proposal to deliver a full European depositary bank passport. A full depositary bank passport will allow European funds, and providers of depositary bank services, to benefit from economies of scale, increased expertise through greater specialisation, and lower costs. With respect to the five Directives that are identified as being under review, we would highlight the benefits of consistency in European rules that would arise from converting relevant parts of these Directives into Regulations. Please see our attached position paper which sets out some more detail on these recommendations.
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Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

4 Jun 2025 · EU capital market integration and depositary services in the EU

Meeting with Regina Doherty (Member of the European Parliament) and S&P Global

9 Apr 2025 · SIU

BNY Urges Simpler EU Rules to Revive Securitisation Market

26 Mar 2025
Topic — The European Commission is reviewing the regulatory framework for financial securitisations.
Message — BNY proposes simplifying due diligence and streamlining disclosure templates for public and private deals. They also advocate for a pan-European insolvency regime to reduce cross-border fragmentation.123
Why — Reducing compliance burdens would allow the bank to move more risks off its balance sheet.4
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Response to Savings and Investments Union

7 Mar 2025

BNY welcomes the opportunity to respond to the European Commission's call for evidence with respect to a future Communication on a Savings and Investments Union (SIU). BNY is a global financial services firm operating in the European Union (EU) primarily through a European bank headquartered in Belgium with branches in nine EU member states. BNY key messages BNY would support a set of ambitious proposals that will allow the savings of European citizens to flow efficiently and effectively through the European financial system, so that they finance productive long-term investment in Europe, and beyond. BNY believes that the proposals for a Savings and Investments Union should focus on achieving three core objectives: 1. an increase in the demand for capital market assets 2. an increase in the supply of capital market assets 3. improving the functioning of European capital markets Please see an attached position paper setting out in more detail our suggestions.
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BNY Mellon Urges EU to Remove Financial Service Barriers

31 Jan 2025
Topic — The consultation seeks to further develop the single market for services and goods.
Message — BNY requests a full depositary passport to allow banks to provide services across borders. They also urge for uniform interpretation of rules and consistent regulations for securities collateral.123
Why — Operating under one license would lower costs and facilitate expansion across the region.4
Impact — Local banks protected by national restrictions would face increased competition from foreign firms.5
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Meeting with Ivars Ijabs (Member of the European Parliament, Shadow rapporteur) and Microsoft Corporation and

13 Dec 2024 · European defence industry programme (EDIP)

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

21 Feb 2024 · Physical meeting - Discussion focused on the FASTER proposal

BNY Mellon urges unified EU withholding tax process

18 Sept 2023
Topic — The initiative introduces a standardized EU-wide system for withholding tax relief.
Message — BNY Mellon requests a common pan-European operational process for withholding tax on securities. They warn that national specificities could undermine the proposal's goal of simplicity. They also seek better integration with existing trading and custody workflows.123
Why — Streamlined processes would improve the attractiveness of European capital markets for global clients.45
Impact — Investors face higher costs if national specificities create a fragmented and complex market.67
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

2 Jun 2023 · Capital Markets Union

Meeting with Aurore Lalucq (Member of the European Parliament, Shadow rapporteur) and Afore Consulting

4 May 2023 · EMIR

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

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Association Française de la Gestion financière and

9 Feb 2023 · Corporate Sustainability Due Diligence

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

26 Jan 2023 · Current legislative agenda, CMU

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 Jonás Fernández (Member of the European Parliament, Rapporteur) and Finance Watch

5 Oct 2022 · EU Banking Package 2021

Meeting with Frances Fitzgerald (Member of the European Parliament)

5 Oct 2022 · CRR/CRD

Meeting with Gilles Boyer (Member of the European Parliament)

5 Oct 2022 · Corporate sustainability and due diligence directive

Meeting with Johan Van Overtveldt (Member of the European Parliament)

5 Oct 2022 · CRD, CRR, banking union

Response to Central securities depositories – review of EU rules

26 May 2022

BNY Mellon welcomes the CSDR REFIT Proposal adopted by the European Commission. We believe that the Proposal introduces important and necessary changes to CSDR. Yet we also believe that the Proposal has some gaps, and can be improved. Late settlement penalties One key gap is the lack of a mandate to ESMA to create a public database that identifies all securities subject to late settlement penalties, the penalty category in which they fall, and the prices that should be used to calculate penalties. Such a database is necessary to minimise errors in the calculation of penalties, and to avoid reconciliation differences at the level of an intermediary and of an end investor. The Proposal contains text that would limit the types of transactions that are subject to late settlement penalties. Yet this new text is drafted in a broad and vague manner, so that potentially many types of transactions would be out of scope, while it is unclear as to precisely which ones would be out of scope. Given that late settlement penalties are a highly important tool to achieve high settlement rates, it is important that most types of transaction do fall within the scope of the penalties mechanism, while there is also a very clear list of the types of transaction that fall out of scope. Technical transactions, including pure cash transfers, tax adjustments, registration movements, as well as centrally-generated transactions (for late matching penalties), should all be out of scope, as penalties for these types of transaction serve no purpose, and hinder the smooth operation of the penalty mechanism. There are also some additional minor changes that should be undertaken to improve the operation of the penalty mechanism, including ensuring that all penalties for a given security are calculated at the same rate. Mandatory buy-ins The two-stage procedure set out in the Proposal for the implementation of the rules on mandatory buy-ins is a major improvement. Mandatory buy-ins are a highly disruptive and inappropriate tool to improve settlement rates. For this reason, it is important that all other possible steps, including a recalibration of the penalty rates, are taken before there is any move towards stage two. Given the extra-territorial nature of the mandatory buy-in rules, and their requirement for extensive repapering between parties in the custody chain, it is important that there is full clarity that stage one of the mandatory buy-in rules does not mandate that parties in the custody chain effect any repapering. Other important improvements to the mandatory buy-in rules would be the elimination of the requirement of CSDs to collect and store buy-in-related information, and the elimination of the requirement to appoint a buy-in agent. Banking services The Proposal would allow a CSD that has a banking licence to offer banking services not only to its participants but also to participants in other CSDs. This measure is ill-conceived, and should be dropped, as it contradicts the desirable public policy objective of greater settlement in central bank money, and as it introduces contagion risk. Access and interoperability The Proposal contains welcome and important steps to facilitate the cross-border provision by CSDs of services to issuers, and thereby to increase competition in the provision of such services. We believe that it is important to increase access and interoperability rights for all participants in European capital markets. We note that so far CSDR and other public policy measures have focused on providing access and interoperability rights to investors, and to infrastructures and intermediaries acting on behalf of investors, thereby facilitating the access of investors to issuers. We believe that there is a need for CSDR to provide greater access and interoperability rights to issuers, and to infrastructures and intermediaries acting on behalf of issuers, thereby facilitating the access of issuers to investors.
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Response to New EU system for the avoidance of double taxation in the field of withholding taxes

26 Oct 2021

BNY Mellon supports the implementation of a standardized EU-wide system for withholding tax relief at source. We believe that that this is a necessary feature of a European Capital Markets Union. Accordingly, we support Policy Option 2. However, Policy Option 2 should be complemented by Policy Option 3, as any effective common system of relief at source will need to be founded on extensive exchanges of information. In addition, Policy Option 2 should be complemented by Policy Option 1, as any relief at source system cannot cover all possible scenarios, so that investors will still need as a back-up the possibility to introduce tax reclaims. We welcome the announcement that the European Commission intends to launch in Q4 2021 a 12-week long public consultation. We believe that this consultation should cover the main issues relating to the design of an ambitious, common, pan-European relief at source system. Among the issues that should be covered are the following: 1/ Common definitions, including a common definition of the investor or beneficiary 2/ Common requirements, such as common minimum holding periods for eligibility for tax relief 3/ Integration between the income payment process and the tax relief process 4/ Application of the record date principle, so that entitlements to tax relief are based on record date positions 5/ Common and workable liability standards for intermediaries, so that as many intermediaries as possible are able to participate in the system 6/ A common process for the auditing of the work of intermediaries 7/ Common reporting requirements for intermediaries We believe that any common system that provides EU and non-EU investors with relief at source for income on all EU securities will necessarily be based on the integrity of the custody chain, and will rely on intermediaries playing a key role, as is the case in, for example, the OECD’s TRACE model. We believe that new technologies can play a key role in facilitating the transmission, storage and maintenance of the information that is needed to pay securities income with the correct deduction of withholding tax. Accordingly, any future common system should exploit the potentialities of new technology. But new technology cannot by itself solve all problems, so that there is still a need to resolve the issues listed above. We believe that any common pan-European system should prevent to the greatest extent possible fraud and abuse. Attached is a paper dated November 2016 from the ECB’s TARGET-2 Securities Advisory Group that in particular explains how the strict application of the record date principle can provide a major contribution to the elimination of some kinds of fraud. We believe that the analysis in this paper is in a valuable contribution to the debate, and is a useful starting point for further analysis and reflection. With respect to a common definition of investor, we believe that, a priori, there are clear advantages if the definitions used for operational, legal and tax purposes were the same, as this would reduce complexity, and the risk of confusion and conflict. This, however, could create anomalies with respect to some types of activity, such as the provision of securities collateral. Accordingly, we suggest that the Q4 consultation paper reviews this question in depth. We would also suggest that the Q4 consultation paper covers a common system for tax relief not just on cash distributions, but also on securities distributions, and on corporate actions in general. Tax processing on securities distributions is currently an area of particular complexity and uncertainty, so that a clear, well-defined, common pan-European system would deliver benefits to all participants in securities markets.
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Response to Central securities depositories – review of EU rules

5 Apr 2021

BNY Mellon welcomes the planned review of CSDR. We believe that CSDR has played an important role in the development of safe and efficient financial market infrastructure in Europe, and that there is scope to modify CSDR in order for the objectives of CSDR to be met in a more effective and efficient manner. We wish to highlight two areas in which changes will have the greatest beneficial impact on European capital markets. These areas are: 1/ Buy-in rules for non-CCP transactions 2/ Securities account structures (Article 38) Here is a brief discussion of these topics that complements our response to the recent public consultation. 1/ Buy-in rules for non-CCP transactions The CSDR buy-in rules for non-CCP transactions are fundamentally anomalous in their design, in their requirements, and in their effects. It is critical that these buy-in rules be modified, in order to protect the safety, efficiency and attractiveness of European markets. Some of the anomalies are as follows: • A mandatory obligation placed on a buyer to execute a buy-in, even when executing a buy-in is against the interests and wishes of the buyer. Executing a buy-in involves the risk that the buy-in will fail, and the buyer will not actually receive the securities it had purchased. • A scope of the buy-in obligation on non-CCP transactions that is much broader (more securities, more diverse types of activity) than the scope of the buy-in obligation on CCP transactions. • An extra-territorial scope of this obligation so that it also applies to non-European trading parties and non-European transactions. (No other CSDR settlement discipline rule has such an extra-territorial scope). • A burdensome obligation (Article 25 of Level 2) that requires changes for non-European investors to all trading contracts, and all contractual arrangements in all custody chains. (Article 25 would become unnecessary, if the extra-territorial scope of the buy-in rules for non-CCP transactions was eliminated). • The use of the custody chain for the transmission for trading-related information (namely, on the results of buy-ins) to the CSD. (There are alternative, and much more efficient, processes for the transmission of trading-related information). We are attaching to this response a compilation of three short papers that discuss the effect of these rules on systemic risk, market access and operational burden. 2/ Securities account structures (Article 38) The protections and rights set out in Article 38, and in particular the right to operate both omnibus client, and individual client, securities accounts, represent an important step forward towards improving the access of investors to European capital markets. For smaller, cross-border investors, the costs of holding securities through segregated accounts up the custody chain are high. Accordingly, and in order to provide market access to such investors, it is very important that intermediaries have the ability to operate omnibus client accounts, while guaranteeing that the investor keeps full rights to the securities. However, CSDR Article 38 does not offer a full solution. Article 38 takes an operational perspective, but misses a legal perspective (namely, the question of who is considered the legal owner of securities), and a fiscal perspective (namely, the question of how to ensure that an end investor is taxed at the correct rate). This means that for some investors there are still barriers to accessing European markets. In some cases, even if securities are held in omnibus accounts at the CSD, national legal and fiscal rules have the practical effect of requiring that securities be held in segregated accounts at a sub-custodian. Article 38 will need to be complemented by rules that (i) recognise the end investor as the legal owner of securities, and (ii) facilitate the correct application of tax rules. Such additional rules could be incorporated in the revision of CSDR, or in another piece of legislation.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

26 Feb 2021 · Sustainable finance & the capital markets union

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

26 Jan 2021 · CMU/Sustainable Finance

Meeting with Lesia Radelicki (Cabinet of Commissioner Helena Dalli)

3 Sept 2020 · Best practices (Gender equality) in the financial sector

BNY Mellon Urges Excluding Asset Managers From Banking Rules

18 Dec 2019
Topic — This consultation addresses alignment of EU bank capital rules with international Basel standards.
Message — The bank requests that asset managers be excluded from certain banking parent requirements. They argue these firms are not bank-like and inclusion creates an unlevel playing field. They also suggest allowing more flexibility for capital buffers in bank subsidiaries.123
Why — This would reduce administrative costs and prevent unnecessary lock-up of capital across jurisdictions.45
Impact — Financial regulators lose the security of a fixed and higher mandatory capital safety net.6
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

5 Nov 2019 · CMU, sustainable finance

Response to Safekeeping duties of depositaries for UCITS funds

22 Jun 2018

BNY Mellon welcomed the publication of the ESMA Opinion on Asset Segregation in July 2017. We also welcome the European Commission’s publication of draft delegated regulations in respect of the safe-keeping duties of depositaries (following on from this ESMA Opinion). BNY Mellon thanks the European Commission for engaging in this consultation process. BNY Mellon generally welcomes the European Commission’s proposed draft delegated regulations in respect of the safe-keeping duties of depositaries. Amending the current delegated regulations is important, in order to provide greater clarity to the market in this regard, and to give effect to the key elements of the ESMA Opinion. In particular, we welcome the recognition of the omnibus account structure in the custody chain. We believe this outcome is consistent with operational efficiency, the provision of market liquidity, the effective management of collateral, and whilst providing for investor protection. Although BNY Mellon generally welcomes the proposed draft delegated regulations, BNY Mellon wishes to provide some comments, and alternative drafting, to address a number of concerns with, and to provide greater clarity on, certain aspects of the current drafting of the draft delegated regulations. BNY Mellon supports the Commission’s recognition of the use of the omnibus account structure throughout the custody chain. In this regard, we recommend some drafting changes to provide further clarity. In regard to reconciliations, we think the current delegated regulation and the proposed delegated regulation lacks clarity regarding which parties have responsibility to perform reconciliations and which parties have responsibility to verify that reconciliations are performed, throughout the custody chain. We set out a model that ensures reconciliations occur throughout the custody chain, without unnecessary duplication, and we provide some alternative drafting to achieve this. We also have the view that reconciliations should occur as often as necessary, but without mandating a frequency, in order to maintain flexibility for different business models. Most importantly, we seek the retention of the current ability for the depositary to use the “reliance model” (i.e., whereby the depositary delegates the responsibility for maintenance of the first-level custody books and records to the depositary, but retains legal responsibility to the depositary’s client to ensure that such books and records are maintained). The “reliance model”, also known as the “delegation model”, is widely used in the UK, Ireland and Luxembourg (the key funds markets in the EU) and other markets, and is particularly important where UCITS clients wish to use value-added services such as triparty collateral management services and/or prime broker services. Furthermore, mandating that the depositary duplicates the books and records of the custodian provides no discernable benefit but increases operational risk where value-added services are used. In some cases, this may prevent UCITS clients from access value-added services. We emphasise that the optionality of the “reliance model” should be retained - but if the Commission decides not to do this and prevent the use of the “reliance model” going forward, then it will be essential for the Commission to provide for a much longer implementation period for the draft delegated regulation in order to avoid a disruptive cliff-edge effect. BNY Mellon also supports more focused provisions regarding the minimum contractual requirements where the depositary appoints a third party delegate. We also provide some drafting proposals with respect to the provision of statements and other drafting issues. Please see our attached letter for further details, including our drafting proposals.
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Response to Safekeeping duties of depositaries for Alternative Investment Funds

22 Jun 2018

BNY Mellon welcomed the publication of the ESMA Opinion on Asset Segregation in July 2017. We also welcome the European Commission’s publication of draft delegated regulations in respect of the safe-keeping duties of depositaries (following on from this ESMA Opinion). BNY Mellon thanks the European Commission for engaging in this consultation process. BNY Mellon generally welcomes the European Commission’s proposed draft delegated regulations in respect of the safe-keeping duties of depositaries. Amending the current delegated regulations is important, in order to provide greater clarity to the market in this regard, and to give effect to the key elements of the ESMA Opinion. In particular, we welcome the recognition of the omnibus account structure in the custody chain. We believe this outcome is consistent with operational efficiency, the provision of market liquidity, the effective management of collateral, and whilst providing for investor protection. Although BNY Mellon generally welcomes the proposed draft delegated regulations, BNYMellon wishes to provide some comments, and alternative drafting, to address a number of concerns with, and to provide greater clarity on, certain aspects of the current drafting of the draft delegated regulations. BNY Mellon supports the Commission’s recognition of the use of the omnibus account structure throughout the custody chain. In this regard, we recommend some drafting changes to provide further clarity. In regard to reconciliations, we think the current delegated regulation and the proposed delegated regulation lacks clarity regarding which parties have responsibility to perform reconciliations and which parties have responsibility to verify that reconciliations are performed, throughout the custody chain. We set out a model that ensures reconciliations occur throughout the custody chain, without unnecessary duplication, and we provide some alternative drafting to achieve this. We also have the view that reconciliations should occur as often as necessary, but without mandating a frequency, in order to maintain flexibility for different business models. Most importantly, we seek the retention of the current ability for the depositary to use the “reliance model” (i.e., whereby the depositary delegates the responsibility for maintenance of the first-level custody books and records to the depositary, but retains legal responsibility to the depositary’s client to ensure that such books and records are maintained). The “reliance model”, also known as the “delegation model”, is widely used in the UK, Ireland and Luxembourg (the key funds markets in the EU) and other markets, and is particularly important where AIF clients wish to use value-added services such as triparty collateral management services and/or prime broker services. Furthermore, mandating that the depositary duplicates the books and records of the custodian provides no discernable benefit but increases operational risk where value-added services are used. In some cases, this may prevent AIF clients from access value-added services. We emphasise that the optionality of the “reliance model” should be retained - but if the Commission decides not to do this and prevent the use of the “reliance model” going forward, then it will be essential for the Commission to provide for a much longer implementation period for the draft delegated regulation in order to avoid a disruptive cliff-edge effect. BNY Mellon also supports more focused provisions regarding the minimum contractual requirements where the depositary appoints a third party delegate and the provision of legal opinions on insolvency law. We also provide some drafting proposals with respect to the provision of statements and other drafting issues. Please refer to our attached letter for further details, including our specific drafting proposals.
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Response to A simplified prospectus for companies and investors in Europe

18 May 2018

Introduction - The Bank of New York Mellon ("BNY Mellon") is pleased to respond to the European Commission's roadmap-initiative titled "A simplified prospectus for companies and investors in Europe." General Comments - BNY Mellon has an interest in this roadmap-initiative, particularly in relation to its role as depositary bank with regards to Depositary Receipts ("DRs"). The DR instrument is materially similar to a share in its features and the economic exposure it provides to the issuer; yet DRs are categorised as "non-equity securities" under the Prospectus Regulation. Depositary Interests ("DIs") or Crest Depositary Interests ("CDIs"), (which are both very similar to a DR instrument), are however categorised as "equity securities". - It is possible for one issuer to offer shares and DRs in the same offering. If ESMA were to review the DR offer and the National Competent Authority (NCA) were to review the share offer, there would be double review of the same prospectus. We request the European Commission to reconsider this dual authorisation approach. In our experience as a depositary bank, we note that the relevant NCAs have garnered product expertise and market knowledge of DRs to be able to provide appropriate supervisory guidance with respect to the DR issuer prospectus. - The disclosure schedule for DRs must reflect the disclosure requirements for shares and not debt. - We also feel that the disparity in the treatment between DRs and DIs/CDIs should be reconsidered to avoid an unequal treatment of the DR issuers and investors. Where DRs are listed in accordance with the listing rules of an NCA, there is a requirement placed on DR issuers to produce a prospectus when the number of DRs in issuance exceeds the number of DRs notified to the market (the "up-to limit"). An equity issuer on the other hand is exempted from producing a prospectus in similar situations, including bonus issuances and other non-capital raising Corporate Actions. - Given the administrative and monetary burdens faced by DR issuers on the disparity in the treatment to the DR instrument (which is similar to an equity instrument), we take this opportunity to urge the European Commission to reconsider the treatment of DRs in the Prospectus Regulation.
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Response to Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

9 May 2018

BNY Mellon welcomes the approach of Commission in proposing an Implementing Regulation (IR). We believe that such a Regulation will help facilitate the objective of a harmonized pan-European operational process that allows all end investors in voting shares of European companies to exercise the rights associated with those shares. However, we believe that the current draft of the Regulation can be improved in several areas, notably: - by improving the consistency between the Regulation and the two sets of Market Standards that have been drawn up to tackle Giovannini Barrier 3, namely the Market Standards for Corporate Actions Processing and the Market Standards for General Meetings; - by clarifying the responsibilities for compliance by third-country intermediaries; - by clarifying the use of the term “shareholder; and - by ensuring that the differences between depositary receipts and underlying shares are duly recognized. Please find further detail in the attached documents including the main response and two other documents which provide proposed drafting suggestions to both the main proposed text and to the annex.
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BNY Mellon warns of drafting errors in investment rules

8 Mar 2018
Topic — EU consultation on prudential requirements and definitions for investment firm regulations.
Message — The firm requests that unclear definitions regarding credit institutions be redrafted to ensure legal certainty. They also suggest reviewing the term "institution" across EU law to protect existing business activities.123
Why — This ensures the firm can continue providing services without legal or operational disruptions.45
Impact — Investment firms and their clients lose access to services due to technical drafting errors.6
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BNY Mellon calls for gradual expansion of ESMA authority

23 Jan 2018
Topic — Consultation on legislative reforms to the European Supervisory Authorities' regulatory framework.
Message — BNY Mellon supports an evolutionary transfer of powers to ESMA based on efficiency principles. They request that ESMA issue no-action relief letters and maintain public consultation for policy updates. National authorities should keep lead responsibility for market supervision to ensure local expertise remains central.123
Why — Maintaining current outsourcing rules protects the bank's global business and prevents redundant supervisory fees.45
Impact — Investors could face lower fund performance if restrictions are placed on international management delegation.67
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Meeting with Valdis Dombrovskis (Vice-President) and Deutsche Bank AG and

1 Dec 2017 · Introductory remarks and roundtable with EU financial industry and AFISMA/European Chamber of Commerce on financial reforms and banking union

Meeting with Valdis Dombrovskis (Vice-President) and BlackRock and

30 Nov 2017 · Speech at EU-Asia Financial Services Dinner Reception on growth and investment in Europe; Fintech and sustainable finance

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

8 Oct 2015 · Alternative Investment Fund Managers Directive