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).
2023/0111(COD) · In Force
Early intervention measures, conditions for resolution and funding of resolution action (SRMR3)
8 submissions from 8 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
Committee ECONRapporteur Pedro Marques (S&D)
- Publication in the Official Journal · 24 Apr 2026
- Voting result Position of the Council at first reading with a view to the adoption of a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 806/2014 as regards early intervention measures, conditions for resolution and funding of resolution action - Adoption of the Council's position at first reading and of the statement of the Council's reasons - 4159th meeting of the COUNCIL OF THE EUROPEAN UNION (Justice and Home Affairs) 5 March 2026, Brussels · 20 Apr 2026
- Published in the Official Journal · 20 Apr 2026
- Signed · 30 Mar 2026
- Signature by the President of the EP and by the President of the Council · 30 Mar 2026
Who showed up
7 submissions from industry and none from civil society organizations; 1 from public authorities, academia and others.
Industry 7Civil society 0Public authorities, academia, other 1
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 31 Aug 2023 — it ran from 20 Apr 2023.
- Policy area
- Financial services (DG FISMA)
- Where it stands
- Awaiting adoption
- Legislative stage
- In Force
- Lead committee
- ECON
- Rapporteur
- Pedro Marques (S&D)
- Procedure
- 2023/0111(COD)
- Commission reference
- COM(2023)226
How it got here
- Proposal for a regulation31 Aug 2023
Showing 8 of 8 submissions.
NA
National Association of German Cooperative Banks (Bundesverband der Deutschen Volksbanken und Raiffeisenbanken e.V. – BVR)
· · filed 30 Aug 2023 · source
The National Association of German Cooperative Banks (Bundesverband der Deutschen Volksbanken und Raiffeisenbanken e.V. BVR) is in favour of improving crisis management for credit institutions. However, we are afraid that this welcomed goal will not be achieved by the amendments proposed with the CMDI Review.
GB
German Banking Industry Committee (GBIC, Die Deutsche Kreditwirtschaft)
· · filed 30 Aug 2023 · source
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 legislative proposal is therefore rejected in its entirety.
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. As funding opportunities for our members are closely linked to the smooth functioning of the financial system, we are participating in this consultation.
Filed in German · English published by the European Commission
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)
As a general comment on the CMDI framework, ESBG members generally oppose the review overall for various reasons. An operational and effective liquidity-in-resolution tool: ESBG takes note of the recent initiative of the Single Resolution Board (SRB) to assess banks capacity to measure and report liquidity in resolution including the availability of collaterals eligible for monetary policy and the Emergency…
CECA (Spanish Association of Savings and Retail Banks) welcomes the opportunity to comment on the proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) No 806/2014 as regards early intervention measures, conditions for resolution and funding of resolution action. Please find attached our considerations.
GS
German Savings Banks Association (DSGV)
· · filed 14 Jun 2023 · source
SRMR The German Savings Banks Association remains critical of the view of the SRB and the EU Commission that the target level of the SRF is to be understood as dynamic and should therefore be at least 1% of covered deposits at all times. Unfortunately, the CMDI-Review does not contain any adjustments in this respect.
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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.