Position papers
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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.
ECBC Response to the EBA Discussion Paper and Call for Evidence on SMEs and the SME Supporting Factor
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.
The Data Protection Regulation and sound lending practices
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.
FINAL EMF-ECBC RESPONSE TO BCBS CONSULTATION ON INTEREST RATE RISK IN THE BANKING BOOK
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).
Public Consultation on Regulation (EU) No 648/2012 on OTC Derivatives, Central Counterparties and Trade Repositories
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.
EMF-ECBC Position Paper on the Net Stable Funding Ratio (NSFR)
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.
ECBC Response to ESMA Consultation Paper on the Clearing Obligation under EMIR (no. 4)
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.
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.