Find attached the response of EMF-ECBC to European Banking Authority (EBA)’s Consultation on guidelines on specification of types of exposures to be associated with high risk under art. 128 of Regulation (EU) n. 575/2013.
Please find attached the EMF-ECBC Position Paper on EC Proposal for a Directive on Credit Servicers, Credit Purchasers and the Recovery of Collateral
Find attached the respond of EMF-ECBC to the European Banking Authority’s Consultation Paper on Draft Guidelines on Management of Non-Performing and Forborne Exposures
Find attached the pdf version of the paper.
Find attached the pdf version of the paper. Alternatively, download the word file here
Find attached the respond of EMF-ECBC to the EC Consultation on Basel III.
EMF-ECBC Proposals for Amendment to the European Commission’s Proposal for a Regulation amending Regulation (EU) No 575/2013 and Regulation (EU) No 648/2012
EMF-ECBC Position Paper on the treatment of covered bonds and cover assets in the European Commission’s Proposal for a regulation (EU) No 575/2013 as regards the Net Stable Funding Requirement.
EMF-ECBC Response to European Commission's Consultation on the development of secondary markets for non-performing loans and distressed assets and protection of secured creditors from debtors' default.
EMF-ECBC Position Paper on the European Commission Call for Evidence on the Operation of Collective Redress Arrangements in the Member States of the European Union
The EMF-ECBC Position Paper on the European Commission's Public Consultation on FinTech, which was published by the European Commission on 23 March 2017 (see HERE for further information).
This European initiative outlines a set of principles agreed by the banking industry after discussion with the European SME organisations, to ensure that the feedback given by banks to their SME clients is sufficient for them to understand the reasons behind the bank's decision process regarding a credit application.
European Mortgage Federation - European Covered Bond Council (EMF-ECBC) Position Paper
The EMF-ECBC welcomes the opportunity to comment on the Discussion Paper launched by the Joint Committee of the European Supervisory Authorities (ESAs) on 19 December 2016 in relation to the use of big data by financial institutions.
The European Mortgage Federation-European Covered Bond Council (EMF-ECBC) welcomes the objective of the Basel Committee on Banking Supervision and of the European Commission to ensure that financial institutions maintain a stable funding base.
The EMF-ECBC strongly supports the Capital Markets Union (CMU) initiative and the plan of the European Commission to create deeper and more integrated capital markets in the Member States of the European Union (EU).
Treatment of derivatives associated with the cover pool of covered bonds or with securitisations in the draft proposal for a Regulation on simple, transparent and standardised (STS) securitisation as published by the European Commission (COM (2015) 472 final)ECBC Response: STS securisation an,d amendments to the EMIR framework
The European Mortgage Federation (EMF) is pleased to present its comments on the Draft Regulatory Technical Standards on the conditions that competent authorities shall take into account when determining higher risk-weights.
The European Mortgage Federation-European Covered Bond Council (EMF-ECBC) welcomes the European Commission’s new Consultation Document for the review of the EU macro-prudential policy framework.
The European Covered Bond Council (ECBC)1 represents the covered bond industry, bringing together covered bond issuers, analysts, investment bankers, rating agencies and wide range of interested stakeholders.
The EMF-ECBC welcomes the opportunity to respond to this targeted consultation and the constructive approach undertaken by the European Commission. As already recognised in the LCR implementation the Covered bond industry plays a fundamental role in providing long-term, stable financing to the real economy and investors’ confidence especially in market turmoil.
The European Mortgage Federation-European Covered Bond Council (EMF-ECBC)1 believes that capital requirements should be founded on risk-based approaches, which are an effective and flexible tool to gauge a bank’s risk.
We would like to explain that the primary focus of the European Mortgage Federation (EMF) is residential mortgage lending and therefore secured creditors.
Automated Valuation Models have been the subject of increasing attention, the European Mortgage Federation (EMF) and the European AVM Alliance (EAA) have for the first time joined forces1 to provide an overview of the key applications and features of AVMs and of the state of the industry across Europe.
The European Mortgage Federation-European Covered Bond Council (EMF-ECBC)1 is concerned that the Basel Committee on Banking Supervision’s (BCBS) NSFR proposals would unduly restrict the covered bond market and therefore long-term financing.
The EMF-ECBC1 welcomes the opportunity to provide the European Commission with its feedback on the Green Paper on Retail Financial Services: Better Products, More Choice, and Greener Opportunities for Consumers and Businesses which was launched on the 10th of December 2015.
The European Mortgage Federation-European Covered Bond Council (EMF-ECBC)1 believes that there is a strong case to make use of this review clause to improve the treatment of covered bonds in the annual Single Resolution Fund (SRF) contribution scheme.
The European Mortgage Federation-European Covered Bond Council (EMF-ECBC)1 welcomes the objective of the EBA guidelines to harmonise the definition of default to ensure consistency of its application, transparency and comparability of risk parameters between banks across the Member States.
The ECBC welcomes the European Commission’s proposal for further convergence in European covered bond markets and thanks the Commission for the invitation to submit comments on the Consultation Document on Covered Bonds, which, in our view, constitutes one of the most important legislative consultations on covered bonds in decades.
The EMF-ECBC shares the view of the European Commission that an adjustment of any unintended consequences of the introduction of the CRR and CRD IV is a precondition for the building of a Capital Markets Union (CMU) and the successful revitalisation of the European economy.
The ECBC fully supports the goal of strengthening investment and funding in SMEs which constitute a fundamental pillar of the economy of the EU and would express with this contribution the importance of the need of clear, homogeneous and practical rules in order to set the stage for a more favourable lending environment to SMEs. This is particularly important now as there has been a considerable fall in lending to non-financial corporations and especially to SMEs since the start of the crisis.
ACCIS, Eurofinas, European Banking Federation and European Mortgage Federation representing the European lending and credit reporting sectors, support the on-going efforts of the European Institutions to update the European data protection framework and make it fit for the digital era.
The European Mortgage Federation-European Covered Bond Council (EMF-ECBC)1 is pleased to provide its comments herewith on the Basel Committee on Banking Supervision’s (BCBS) Consultative Document on the risk management, capital treatment and supervision of interest rate risk in the banking book (IRRBB).
The ECBC welcomes the opportunity to provide the European Commission with its feedback on the Public Consultation with regard to the European Markets Infrastructure Regulation (EMIR)2 which was launched on 21 May 2015.
The EMF-ECBC is very concerned that the current NSFR proposals from the Basel Committee on Banking Supervision (BCBS) would unduly restrict the covered bond market and therefore unduly restrict long-term financing.
The ECBC welcomes the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) as a response to the ESMA’s Consultation Paper on the Clearing Obligation (no. 4) under the European Markets Infrastructure Regulation (EMIR)2 which was launched on 11 May 2015. For over 200 years, covered bonds have proved to be an efficient debt instrument enabling banks to mobilise private sector means and capital towards long-term investment with a wide public benefit and, in particular, housing loans and public sector debt.
The ECBC welcomes the opportunity to respond to the Request for Comment on “Rating Impact of Rating Agency Removal” launched by Fitch Ratings (Fitch) on 13 April 2015. The ECBC understands that the current Request for Comment serves the purpose of collecting feedback from market participants as to whether the introduction of Rating Agency Removal Language (RRL) should limit achievable ratings.
The EMF is supportive of the identification criteria that seek to identify specific characteristics of securitisation in order to secure better regulatory treatment, and is of the view that the heterogeneous nature of the asset class means that a modular approach is optimal.
Analysing the Potential of a Dual Recourse Funding Instrument, European Secured Note (ESN), as a Source of Long-Term Financing for the Real Economy in the EU.
The European Mortgage Federation1 (EMF) is the voice of the European Union mortgage industry, and represents EU mortgage lenders, ranging from large universal banks (with important mortgage loan portfolios), to specialised lenders whose sole activity is to grant mortgage loans.
The European Commission work programme for 2015 sets out a new start for Europe. As representatives of the undersigned associations which are all active in diverse parts of Europe’s real estate sector, we want this new agenda for change to prioritise a new start for our sector; to reflect an awareness of the important role our sector plays, one that is critical to the EU’s economy and its citizens. It is time for a high level EU dialogue and strategy for Europe’s real estate sector.
The ECBC welcomes the opportunity to respond to the Call for Evidence on “Competition, Choice and Conflicts of Interest in the Credit Rating Industry” launched by the European Securities and Markets Authority (ESMA) on 3 February 2015.
The European Mortgage Federation1 (EMF) is particularly attentive to the combined effect of the Basel Committee on Banking Supervision’s (BCBS) proposed revisions to the standardised approach and the design of a capital floors framework, which will be based on the standardised approach.
As a very first remark, the European Mortgage Federation (EMF) would like to underline that it does not perceive any urgent need for a revision of the standardised approach for credit risk. Most banks that use the standardised approach are small or medium-sized and focus on retail lending.
The European Mortgage Federation (EMF) is pleased to provide herewith its comments on the Joint Committee Consultation on Guidelines for Cross-selling Practices.
The European Mortgage Federation (EMF) welcomes the opportunity to comment on the EBA’s draft Guidelines on product oversight and governance. The EMF wholly subscribes to the objective of protecting consumers from detriment and improving confidence in retail financial markets and the integrity of the financial system in general.
The European Mortgage Federation (EMF) welcomes the opportunity to comment on the EBA’s draft Guidelines on creditworthiness assessment and on arrears.
The ECBC welcomes the opportunity to comment on S&P’s Request for Comment (RFC) on the “Methodology and Assumptions: Analyzing European Commercial Real Estate Collateral in European Covered Bonds” published on 11 December 2014. The proposed criteria changes reflect a determination to harmonise across commercial mortgage-backed securities (CMBS) and covered bond transactions on one side, and across European jurisdictions on the other.
The issue of asset encumbrance has become a major topic of debate in capital markets over the past years. This debate can have a significant impact on the “capabilities” of the covered bond asset class to ensure financial stability and efficient long-term funding without jeopardising the position of other creditors at the bank. In particular, the gradual increase in asset encumbrance has raised questions about the underlying driving forces and consequences for financial stability. As a result, attention quickly turned to the role of covered bonds when, in 2011, their issuance in the EUR market exceeded the issuance of senior unsecured bonds for the first time.