Position papers
Files
ECBC Response to Fitch Ratings Request for Comment “Rating Impact of Rating Agency Removal”
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.
EMF Response to Commission Consultation on High Quality Securitisation
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.
ECBC Response to the Green Paper on Building a Capital Markets Union
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.
European Mortgage Federation Position Paper on the Leverage Ratio
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.
A new start for the real estate/built environment sector
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.
ECBC Response to ESMA Call for Evidence: Competition, Choice and Conflicts of Interest in the Credit Rating Industry
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.
Final EMF Response to BCBS Consultation on Capital Floors: The Design of a Framework based on Standardised Approaches
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.
Final EMF Response to BCBS Consultation on Revisions to the Standardised Approach to Credit Risk
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.
Final European Mortgage Federation Response to Joint Committee Consultation on Guidelines for Cross-Selling Practices
The European Mortgage Federation (EMF) is pleased to provide herewith its comments on the Joint Committee Consultation on Guidelines for Cross-selling Practices.
Final EMF Comments on EBA Consultation Paper on Draft Guidelines on Product Oversight & Governance Arrangements for Retail Banking Products
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.