Deposit protection, use of deposit guarantee schemes funds, cross-border cooperation, and transparency

The European Forum of Deposit Insurers (EFDI) is a platform for practitioners established in October 2002. As a nonprofit umbrella organization EFDI has no commercial interests and its main objective is to contribute to the stability of financial systems by enhancing the role of and promoting European and international co-operation in deposit insurance (and investor compensation), facilitating discussion and…

Banking Union: Review of Crisis Management and Deposit Insurance framework (CMDI) Executive summary Finance Denmark welcomes the underlying objective of the Commission’s proposal for the Review of the Crisis Management and Deposit Insurance framework (hereafter CMDI), which aims at broadening the application of resolution tools in crisis management at European and national level for all European banks, regardless of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

These comments have been prepared by the French Banking Federation (FBF) as a reaction to the European Commissions (EC) proposal to review the EU crisis management and deposit insurance (CMDI) framework, which includes four legislative texts Daisy Chains, the Bank Resolution and Recovery Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR), and the Deposit Guarantee Scheme Directive (DGSD).

The Central Association of German Crafts represents the interests of around one million mainly small craft businesses with more than 5.6 million employees in Germany. Craft businesses depend not only on smooth lending, but also on the security of their deposits with the main bank in order to be able to pay salaries, materials or other items.

Filed in German · English published by the European Commission

The Italian experience and, in particular, FITD interventions have shown in real cases that the current CMDI framework can lead to effective banking crisis management, with the use of all tools and FITD private resources.

August 2023 FGDR Contribution to the EU Commission Consultation for a Renewed CMDI Framework FGDR welcomes the initiative of the Commission to ask for feedback over its proposal for a new EU CMDI framework. Comments below only reflect FGDR’s views, based on its understanding of the proposal.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Italian Banking Association (ABI) welcomes the Commissions effort to optimize the Crisis Management and Deposit Insurance framework by amending three legislative texts, namely the Banking Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism regulation (SRMR) and the Deposit Guarantee Schemes Directive (DGSD).

The ABBL welcomes the underlying objective of the Commissions proposal for a Crisis Management and Deposit Insurance framework (hereafter CMDI), which aims notably at: Broadening the application of resolution tools in crisis management at European and national level including for smaller and medium-sized banks; Extending the use of privately funded safety nets (i.e.

Comment Feedback on the CMDI-review with a specific view on proposed amendments to the Deposit Guarantee Schemes Directive (DGSD) Contact: [name removed] Telephone: [phone removed] E-mail: [email removed] Berlin, 2023-08-25 Coordinator: National Association of German Cooperative Banks Schellingstraße 4 | 10785 Berlin | Germany Telephone: [phone removed] Telefax: [phone removed] https://www.bvr.de/de Page 2 of 6 The…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We, the BVI as the German Investment Funds Association and the German Banking Industry Commit-tee (GBIC), take the opportunity to present our views on the CMDI package proposed by the Europe-an Commission in relation to the proposal for a Directive amending Directive 2014/49/EU (Deposit Guarantee Schemes Directive, DGSD) as regards the scope of deposit protection.

The German Banking Industry Committee (GBIC) welcomes the goal of improving crisis management for credit institutions. However, the changes proposed by the European Commission would considerably impair the performance of the well-established national deposit-based guarantee schemes and call into question the structure of the German banking market. The CMDI legislative package is therefore rejected in its entirety.

Dear Sirs, Please find attached the Polish Bank Association position on: - proposal for a Directive of the European Parliament and of the Council amending Directive 2014/49/EU as regards the scope of deposit protection, use of deposit guarantee schemes funds, cross-border cooperation, and transparency published 18 april 2023; - proposal for a Directive of the European Parliament and of the Council amending Directive…

Electronic Money Association 68 Square Marie-Louise Brussels 1000 Belgium www.e-ma.org 15 August 2023 Dear Madam/Sir, Re: Consultation on the European Commission proposal to amend Directive 2014/49/EU as regards the scope of deposit protection, use of deposit guarantee schemes funds, crossborder cooperation, and transparency The EMA is the EU trade body representing electronic money issuers and alternative payment…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We fully support the objective to strengthen depositor protection and confidence as stated in the Commission's draft legislation. However, the path taken by the EC to achieve these aims is the wrong one. 1. Treatment of IPS The starting point for the Commission to revise the CMDI framework in terms of the treatment of Institutional Protection Schemes (IPS) is the Eurogroup Statement of 16 June 2022.

Preventive measures: adjustments in the DGSD within the framework of the CMDI review primarily focus on preventive measures. The Commissions proposal increases the administrative burden of the DGSs as well as the supervisory and resolutions authorities and, consequently, the need for resources.

CECA (Spanish Association of Savings and Retail Banks) welcomes the opportunity to comment on the proposal for a Directive of the European Parliament and of the Council amending Directive 2014/49/EU as regards the scope of deposit protection, use of deposit guarantee schemes funds, cross-border cooperation, and transparency. Please find attached our considerations.

European Commission Date: 06.07.2023 Ref: 2023/0115 (COD) Comments on the CMDI proposal The Norwegian Banks’ Guarantee Fund (NBGF) welcome the latest CMDI proposal. We believe the proposal clarifies many of the ambiguities in the current directives. The technical proposals from the EBA Opinions on the DGSD have contributed to this.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In addition to technical changes, the adjustments in the DGSD within the framework of the CMDI review primarily focus on preventive (including institutional protection) measures. Without merit, the EU-COM is thus shifting the focus of the DGSD review to market structures of networks of small and medium-sized regionally institutions. The newly formulated requirements for preventive measures are materially very high.