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EU consultation

Targeted amendment on the prudential treatment of reverse repos under the Net Stable Funding Ratio.

24 submissions from 24 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.

The Commission lists 27 submissions on this file. Shown here: the 24 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.

Who showed up

23 submissions from industry — companies and their trade associations — against 1 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 23 industry submissions for every one from civil society.

Industry 23Civil society 1Public authorities, academia, other 0

Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.

What the room declares

14 of 24
in the EU Register
86
full-time lobbying staff
€23.9M+
declared costs a year
61
EP accreditations declared

Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.

The file, right now

The consultation closed on 10 Mar 2025 — it ran from 10 Feb 2025.

Policy area
Financial services (DG FISMA)
Where it stands
In planning
Adoption expected
31 Mar 2025

How it got here

  1. Call for evidence10 Mar 2025

Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Proposal for a regulation.

24 positions

RB

Raiffeisen Bank International

· · filed 10 Mar 2025 · source

We, at RBI Group, would like to express our full support for the European Central Bank's argumentation and proposal to maintain the current transitory Required Stable Funding (RSF) factors for reverse repo operations. Adopting the Basel rates would result in an increase in the volume of RSF at banks, leading to a potentially significant reduction in their NSFR.

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IC

International Capital Market Association (ICMA)

· · filed 10 Mar 2025 · source

PDF

ICMA and its European Repo and Collateral Council (ERCC) welcome the Commissions publication of a Call for Evidence on a targeted amendment on the prudential treatment of SFTs under the NSFR and we strongly support the proposal to "extend the current treatment also beyond 28 June 2025, and permanently".

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SB

Spanish Banking Association

· · filed 10 Mar 2025 · source

PDF

CALL FOR EVIDENCE ON TARGETED AMENDMENT ON THE PRUDENTIAL TREATMENT OF SECURITIES FINANCING TRANSACTIONS UNDER THE NSFR The Spanish banking Association (AEB hereinafter) welcome the possibility to participate in the call for evidence launched by the European Commission (EC) to make permanent the current transitory prudential treatment for securities financing transactions (SFT) and unsecured transactions with a…

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EM

European Money Market Expert Committee (EMMEC)

· · filed 10 Mar 2025 · source

PDF

1. Feedback on the consultation from the European Money Market Expert Committee (EMMEC) EMMEC is STRONGLY supportive of the initiative to make permanent the current regime for prudential factors used in NSFR. Until June 2025 EU banks can apply lower RSF (Required Stable Funding) factors than set out under the Basel standards for certain short term instruments, notably secured financing transactions (SFT), aka repo /…

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F

FBF

· · filed 10 Mar 2025 · source

PDF

The French Banking Federation (FBF) welcomes the opportunity to express the views of the French banking industry on the call for evidence launched by the European Commission (Commission) on a targeted amendment on the prudential treatment of short-term Securities Financing Transactions (SFT) and unsecured transactions under the Net Stable Funding Ratio (NSFR).

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BC

BANCA CF+ CREDITO FONDIARIO S.P.A.

· · filed 10 Mar 2025 · source

PDF

Banca CF+ strongly supports the European Commission proposal aimed at making permanent the current transitory prudential treatment for SFT and unsecured transactions with a residual maturity of less than six months, with financial customers, for the purpose of the Net Stable Funding Requirement (NSFR) (i.e. to extend the current treatment also beyond 28 June 2025, and permanently).

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IS

Intesa Sanpaolo

· · filed 10 Mar 2025 · source

Intesa Sanpaolo strongly supports the European Commissions initiative to extend permanently the application of the current 0%, and 5% RSF factors for reverse repos with maturity shorter than 6m and secured respectively by HQLA Level 1 assets and other collateral.

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FS

Finance Sweden

· · filed 10 Mar 2025 · source

Finance Sweden welcomes the Commissions call for evidence on the targeted amendment regarding the prudential treatment of securities financing transactions under the Net Stable Funding Ratio (NSFR). The association concurs with the Commissions understanding of the issue and the proposed solutions.

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ES

European Savings and Retail Banking Group (ESBG)

· · filed 10 Mar 2025 · source

PDF

ESBG and its members generally support the arguments put forward by the European Commission as regards the decision to make permanent the prudential treatment for short-term securities financing trans-action (SFT) and unsecured transactions with a residual maturity below six months. However, it is important to note that said arguments focus largely on secured funding provided to other financial participants.

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FD

Finance Denmark

· · filed 10 Mar 2025 · source

Finance Denmark appreciates the opportunity to provide feedback on the targeted amendment regarding the prudential treatment of securities financing transactions under the Net Stable Funding Ratio (NSFR). Finance Denmark strongly supports the initiative to make permanent the current transitory prudential treatment for securities financing transactions (SFT) and unsecured transactions with a residual maturity of less…

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DB

Duetsche Boerse Group

· · filed 10 Mar 2025 · source

PDF

Deutsche Börse Group strongly welcomes the European Commissions resolve to make the current transitory NSFR regime for securities financing transactions (SFTs) permanent. Upon the implementation of the NSFR in June 2021, European banks did not face significant challenges in adapting to the requirements due to the ECBs generous Targeted Long Term Refinancing Operations (TLTRO).

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AF

Austrian Federal Economic Chamber, Division Bank and Insurance

· · filed 10 Mar 2025 · source

Dear Sir or Madam, The arguments summarized in the EC Call for Evidence paper are true and fully supported. They largely focus on secured funding provided to other financial participants. However, it should be emphasized that many of the arguments mentioned also apply to unsecured placements. To be more precise: 1.

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GC

Groupe Crédit Agricole

· · filed 7 Mar 2025 · source

We welcome and fully support the European Commissions proposal to maintain the RSF factors applicable to short-term secured and unsecured lending transactions with financial counterparties to their current level of 0%, 5% and 10% permanently, absent which they will revert to the higher 10% and 15% factors set out in the Basel standards by June 2025.

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MS

MEDIOBANCA SPA

· · filed 7 Mar 2025 · source

Mediobanca Banca di Credito Finanziario Spa, on behalf of its banking group, supports the European Commission's initiative to make permanent the current transitory prudential treatment for SFT and unsecured transactions with a residual maturity of less than six months, with financial customers, for the purpose of the Net Stable Funding Requirement (NSFR).

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IS

International Swaps and Derivatives Association

· · filed 7 Mar 2025 · source

PDF

Repo transactions play a vital role within the financial system and underpin the functioning of primary and secondary capital markets in addition to the shorter-term money markets. More broadly, the repo market promotes the more efficient use of available tradeable stock for collateral management, and is closely linked to the sovereign debt market1.

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U

UniCredit

· · filed 7 Mar 2025 · source

UniCredit supports the European Commission's Call for Evidence for an initiative in relation to the treatment of reverse repos and unsecured lending under the Net Stable Funding Ratio (NSFR) requirement. We agree with the Commission's description and assessment of the very significant issues that would be caused through the reversion of RSF factors for reverse repo and unsecured transactions to the levels of 10% and…

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BM

Banca Monte dei Paschi di Siena S.p.A.

· · filed 7 Mar 2025 · source

PDF

Banca Monte dei Paschi di Siena S.p.A. (BMPS) is the fifth-largest bank in Italy, with reported total assets of around 123 billion as of 31st December 2024. MPS offers retail and commercial banking, and other financial services to retail customers, SMEs and large corporations, mainly in Italy.

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EB

European Banking Federation

· · filed 6 Mar 2025 · source

PDF

The European Banking Federation supports the initiative to make permanent the current transitory prudential treatment for securities financing transactions (SFT) and unsecured transactions with a residual maturity of less than six months, with financial customers, for the purpose of the Net Stable Funding Ratio (NSFR).

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EA

European Association of Co-operative Banks (EACB)

· · filed 6 Mar 2025 · source

The European Association of Co-operative Banks (EACB) supports the European Commission (EC) initiative to make permanent the current transitory prudential treatment for secured funding transactions (SFT) and unsecured transactions with a residual maturity of less than six months with financial customers, for the purpose of the Net Stable Funding Requirement (NSFR).

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IB

Italian Banking Association ABI

· · filed 6 Mar 2025 · source

PDF

ABI (shared at European level EBF) strongly supports the European Commission proposal aimed at making permanent the current transitory prudential treatment for SFT and unsecured transactions with a residual maturity of less than six months, with financial customers, for the purpose of the Net Stable Funding Requirement (NSFR) (i.e. to extend the current treatment also beyond 28 June 2025, and permanently).

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AF

Association for Financial Markets in Europe (AFME)

· · filed 6 Mar 2025 · source

PDF

AFME and its members have noted the European Commissions Call for Evidence for an initiative in relation to the treatment of reverse repos and unsecured lending under the NSFR standard. The industry considers it essential that an initiative is issued from the European Commission to extend permanently the application of the current 0%, 5% and 10% RSF factors for reverse repos secured by Level 1 HQLA and non-Level 1…

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RA

Romanian Association of Banks (RAB)

· · filed 5 Mar 2025 · source

PDF

The Romanian Association of Banks (RAB) supports the proposed amendment that would render permanent the currently transitory treatment of short-term securities financing with financial customers for the calculation of the net stable funding ratio. One of our main arguments refers to the need for an international level playing field in the treatments imposed by the European regulation.

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AF

ASSIOM FOREX

· · filed 4 Mar 2025 · source

Assiom Forex recommend the introduction of a legislative proposal to ensure that RSF can remain at the current levels of 0% and 5%, for less than 6 month transactions secured by level 1 HQLA and non Level 1 HQLA respectively. The reasons of our recommendation are mainly related to: - Need to have of a common playing field with the treatments in other major jurisdictions, e.g.

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AS

Austrian Savings Banks Association

· · filed 25 Feb 2025 · source

The arguments summarised in the EC Call for Evidence paper are true and fully supported. They broadly focus on secured funding provided to other financial participants. However, it should be emphasised that many of the arguments mentioned thus apply to unsecured placements. To be more precise: 1. The disadvantages compared to other jurisdictions outside the EU that have adopted the lower RSF weights permanently 2.

Filed in German · English published by the European Commission

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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.