Revision of the guarantee notice

The European Association of Guarantee Institutions (AECM) welcomes the opportunity to contribute to the revision of the Commission Notice on Guarantees (Guarantee Notice). We strongly support the Commissions objective of ensuring that the framework remains fit for purpose, market-conform, and operationally efficient, while continuing to support access to finance.

The Department of Agriculture Food and Marine (DAFM) deliver guaranteed loan schemes with the (SBCI)that fall under the commission notice on guarantees. The SBCI works closely with the DAFM and Department of Enterprise Tourism and Employment to deliver longer-term investment financing via guaranteed loan schemes to Irish SMEs and welcomes the revision of the guarantee notice. Most welcomed are the following: 1.

We call for a review and broadening of the scope of companies covered by the provisions of the European Commission’s Communication, taking into account what the European Commission has already extended to small mid-cap and mid-cap companies.

Filed in Latvian · English published by the European Commission

We welcome the opportunity to provide inputs for the Revision of the Commission Notice on the application of Articles 87 and 88 of the EC Treaty to State aid in the form of guarantees. It is proposed that the Notice be made consistent with certain provisions of the GBER, e.g. with the risk financing rules defined in the Article 21.

In connection with the public consultation on the draft amendment to the Commission Notice on the application of Articles 87 and 88 of the EC Treaty to State aid in the form of guarantees, Polskie Porty Lotnicze S.A. would point out that: 1. From the point of view of the public undertaking, it is necessary to clarify and simplify the conditions for concluding that a guarantee does not constitute State aid.

Filed in Polish · English published by the European Commission

Cassa Depositi e Prestiti (CDP) is the Italian National Promotional Institution (NPI) and one of the largest Italian financial institutions. CDP fosters sustainable development in Italy, promoting growth and employment, innovation, business competitiveness, infrastructure, and local development.

The Guarantee Notice is an important legal basis for the activities of national and regional promotional banks and funding agencies, represented by EAPB. We would like to share several proposals to prevent divergent interpretations across Member States and reduce unnecessary administrative workload for beneficiaries.

1. Lack of clarity regarding the application of State guarantees to large companies Currently, there is no clear assessment of whether State aid guarantees can be applied to large companies facing limited market financing. The current Guarantee Notice does not provide a clear set of criteria for assessing the eligibility of such undertakings for aid.

Filed in Lithuanian · English published by the European Commission

Guarantee banks provide default guarantees and guarantees to finance promising projects undertaken by small and medium-sized enterprises in the commercial sector and the liberal professions. The collateral provided by the guarantee banks constitutes fully valid security for all principal banks and reduces the capital requirements for the credit institutions.

Following the call for evidence, the City of Helsinki makes the following observations: Aid to the Lender The new Guarantee Notice should include a methodology or methodologies to ensure that, in situations under point 2.1 of the Guarantee Notice, the Lender does not benefit from the guarantee. Individual guarantees How exactly is a credit claim defined/calculated?

Filed in Finnish · English published by the European Commission

Based on experience with guarantees that were implemented in the 2007-2013 perspective. In the case of simple guarantees, where the aid value was determined on the basis of safe-harbour premiums set by the Commission, practice showed that the calculations were still complex. Determining the value of the aid required a number of steps, e.g.

Filed in Polish · English published by the European Commission

The Italian Banking Association considers that the European Commission’s review of the Notice on State aid in the form of guarantees is of particular relevance in the light of developments in the financial markets, the regulatory framework on State aid and the experience gained in applying it in recent years.

Filed in Italian · English published by the European Commission

UECNA is the only Europe-wide organisation which represents airport communities at the European Parliament, the European Commission and at the International Civil Aviation Organisation. It also supports organisations and citizens with expert advice and by exchanging information, experience and best practices. UECNA addresses the negative impacts of aviation noise and pollution.

Municipality Finance Plc believes that there are two aspects where the Notice would benefit from clarifications. These aspects are (i) the scope of application of the Notice, and the (ii) criteria when lenders would constitute aid beneficiaries of public guarantees. These aspects are discussed in more detail in the separate PDF file we have attached. To summarize, our observations are as follows.