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Verband deutscher Pfandbriefbanken e.V.

vdp

Zu den Zielen des Verbandes deutscher Pfandbriefbanken gehören · die Wahrnehmung der Rechte und Interessen der Pfandbriefbanken einschließlich der Öffentlichkeitsarbeit auf den Gebieten der Kapitalmarkt-, Staats-, Immobilien- und Schiffsfinanzierungs-, sowie der Rechtsgestaltung. · die Unterstützung und Beratung der gesetzgebenden Körperschaften und Behörden auf nationaler, europäischer und internationaler Ebene in allen die Pfandbriefbanken betreffenden Angelegenheiten. · die Wahrnehmung der Interessen der Pfandbriefbanken gegenüber anderen nationalen, europäischen und internationalen Berufsverbänden. · die Mitgliedschaft in nationalen, europäischen oder internationalen Berufsverbänden oder die Beteiligung an Unternehmen gleich welcher Gesellschaftsform, soweit Mitgliedschaft oder Beteiligung dem Verbandszweck oder den Mitgliedern des Verbandes dienen.

Lobbying Activity

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

2 Dec 2025 · Verbriefung

Meeting with Stefan Moser (Head of Unit Energy)

2 Jul 2025 · Housing finance

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen)

2 Jul 2025 · Discussion on ways to mobilise private investments for affordable and sustainable housing, in view of the upcoming Affordable Housing Plan and the Pan-European Investment Platfrom for Affordable and Sustainable Housing

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

19 Feb 2025 · Austausch zu aktuellen Fragen der europäischen Finanzmarktpolitik

Meeting with Aurore Lalucq (Member of the European Parliament, Committee chair) and Bundesverband deutscher Banken e.V. and

19 Feb 2025 · Commission Work Programme and coming legislative proposals

Meeting with Ugo Bassi (Director Financial Stability, Financial Services and Capital Markets Union) and

20 Jan 2025 · EU-Implementation of Basel III Reform

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

16 Oct 2024 · Working breakfast with German banking industry committee

Meeting with Rasmus Andresen (Member of the European Parliament)

26 Sept 2024 · CMU

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

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Joachim Schuster (Member of the European Parliament)

29 Nov 2022 · Banking regulation

Meeting with Joachim Schuster (Member of the European Parliament) and Deutsche Bank AG and

21 Jun 2022 · Banking package

Meeting with Rasmus Andresen (Member of the European Parliament)

20 Apr 2022 · Umsetzung des Basel-Abkommens

Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

6 Jan 2022

The Association of German Pfandbrief Banks thanks for the opportunity to comment briefly on the proposals to amend the CRR and has summarised its comments in the annex.
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Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

1 Sept 2021 · Basel III revised standards

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

7 Apr 2021 · Basel III

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

10 Mar 2021 · Basel reforms implementation

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

vdp comments on Delegated Act (DA) Germany’s Pfandbrief banks are committed to the Paris Agreement and prepared to make their contribution towards strictly limiting global warming. However, in the vdp's view, the present draft of the DA with the corresponding criteria and specifications is unsuitable for achieving the transformation of the building sector in terms of the intended shift of investments into sustainable economic activities to achieve the climate protection goals. Regarding the potential financing of such activities by Pfandbrief banks, in their current wording the rules and regulations do not promote the design of corresponding green financing and funding products, as the requirements for green buildings would simply not be feasible in practice, and therefore no taxonomy-compliant assets would be available to be refinanced via EU Green Bonds. For a successful and applicable taxonomy, a harmonised European and national legal framework would be required first and should implement: • Comparable NZEB standards, standardised EPCs and, based on these, uniformly derived C02 threshold values. • National implemented legal construction standards and manufacturer specifications. • EU-wide or national publicly accessible registers to collect the relevant data. • Clarification on how to classify non-EU real estate assets as taxonomy compliant. • In the transition period towards the above described and not yet reached status a clear commitment to best national practices. • Green Building certificates such as LEED, BREEAM, DGNB should optionally be allowed for taxonomy compliance, at least for a transition period. Mitigation of climate change – screening criteria A&O of buildings In Germany, EPCs for non-residential buildings do not indicate energy efficiency classes. Since other countries have a similar situation, the requirement of an EPC label “A” is not feasible for this asset type until a change in national legislation. We advocate to follow the TEG’s proposal that buildings belong to the TOP 15% of the national building stock in terms of primary energy demand. The screening criteria on energy performance monitoring and assessment for larger buildings cannot be met by credit institutions. Such systems are mandatory for non-SMEs only, i.e. this requirement has to be fulfilled by the tenant and not by the asset owner. Construction of new buildings In national NZEB definitions, the requirements of the EPBD for achieving the Paris climate goals have already been legally implemented and therefore reflect the decarbonisation targets. Requiring NZEB minus 20% therefore does not seem adequate. We do not see any incentives for building owners to aim 20% below the officially endorsed national NZEB threshold. Developers are currently not able to deliver a life cycle GWP of the building since there is no legal requirement in Germany. The criterion would massively decrease eligible business. Renovation The 30% reduction requirement should be based on the final energy demand/consumption and thereby exclude the energy source (fn 535). It seems to be inconsistent and too complex to require a reduction of the primary energy demand without due consideration of reductions stemming from renewable energy sources. DNSH requirements The DNSH criteria often appear to be particularly impractical or can currently only be verified with increased effort on the part of investors/owners. In our view, it is of particular relevance that EU legislators ensure that required criteria and standards are incorporated into national legislation. Sustainable use and protection of water Lacking national regulations/laws for manufacturers/the construction industry and resulting lack of data collection by owners/builders, no proof of water consumption can be provided. Climate change adaptation There is no guidance which criteria have to be fulfilled by such an assessment. There is no standard available on how to conduct the required scenario analysis.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

The Association of German Pfandbrief Banks (vdp) represents the sector’s most important providers of financing for residential and commercial property. We share the view that a significant increase in the renovation rate of existing buildings is necessary to achieve the climate goals in the property sector. This applies to both residential and commercial properties. Unfortunately, it is often the case that the costs of an energy efficient renovation are significantly higher than the subsequent savings due to lower electricity and heating costs. Therefore, many owners do not renovate. A renovation wave starting in the right places, could remedy the situation and give a much-needed boost to the energy efficiency of buildings. To this end, tax incentives and subsidies should be used to encourage owners to do so. Even if appropriate support is already available in some EU countries, it is clear that this is not yet sufficient to close or at least reduce the gap between the costs of refurbishment and subsequent savings. The funds available under the renovation wave should therefore be used to strengthen these incentives. Since the gap probably cannot be completely closed in this way, access to favourable financing conditions should be made easier for owners of residential and commercial property. Many German Pfandbrief banks already grant borrowers favourable conditions for the construction and acquisition of energy-efficient buildings or the energy refurbishment of buildings, provided that certain conditions are met. However, there are limits to this, not least because of the low interest rate environment that is likely to persist for a long time and the still unclear effects of the COVID 19 pandemic. Here, public sector guarantees are an option, e.g. by assuming a first loss or by guaranteeing the financing portion in excess of 60% of the mortgage lending value, as this part of a loan has to be refinanced by the banks in the capital market at considerably higher costs. The availability of data for assessing the energy efficiency of residential and commercial buildings and its comparability play an important role. Projects aimed at improving data availability should be encouraged or initiated. At the regulatory level, existing barriers should be removed. In this context, we welcome the fact that the importance of the role of the EPC as a data source in the European context is emphasised and should be strengthened as a tool. For the achievement of the ambitious climate targets in the building sector, we consider a standardization and better comparability of EPCs in Europe indispensable. The importance of EPCs should also be reflected in the EU Taxonomy, in which the technical criteria for the definition of "green" buildings should mainly be based on EPCs, both for renovation and for construction and acquisition of energy efficient buildings. Our full statement can be found in the attached document.
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Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

25 Mar 2020 · Implementation of Basel 3

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

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

Meeting with Mette Toftdal Grolleman (Cabinet of Vice-President Valdis Dombrovskis)

7 Sept 2016 · Covered Bonds

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

1 Apr 2016 · Consultation on Covered Bonds; NSFR

Meeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)

15 Jan 2015 · Covered Bonds