Position papers
Files
EMF-ECBC response to the DG FISMA’s Consultation Paper on Further Considerations for the Implementation of the NSFR in the EU
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.
EMF-ECBC response to the Basel Committee on Banking Supervision Consultative Document on “Reducing variation in credit risk-weighted assets – constraints on the use of internal model approaches"
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.
EMF Response to the European Commission’s Consultation on an Effective Insolvency Framework within the EU
We would like to explain that the primary focus of the European Mortgage Federation (EMF) is residential mortgage lending and therefore secured creditors.
EMF/EAA JOINT PAPER ON THE USE OF AUTOMATED VALUATION MODELS IN EUROPE
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.
Final EMF-ECBC Position Paper on the Net Stable Funding Ratio (NSFR)
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.
Green Paper on Retail Financial Services: Better Products, More Choice, and Greener Opportunities for Consumers and Businesses
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.
EMF-ECBC POSITION ON THE TREATMENT OF COVERED BONDS IN THE SINGLE RESOLUTION FUND SCHEME AS DESIGNED BY COMMISSION DELEGATED REGULATION (EU) N° 2015/63 OF 21 OCTOBER 2014 WITH REGARD TO EX ANTE CONTRIBUTIONS TO RESOLUTION FINANCING ARRANGEMENTS
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.
EMF-ECBC Response to the European Banking Authority’s Consultation Paper on Guidelines on the Application of the Definition of Default under Article 178 of Regulation (EU) 575/2013
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.
ECBC RESPONSE TO THE EUROPEAN COMMISSION’S CONSULTATION DOCUMENT ON COVERED BONDS IN THE EUROPEAN UNION
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.
Final EMF-ECBC Response to European Commission Consultation on Impact of CRR/CRD IV on Long-Term Financing
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.