The current definition of “mortgage portfolio standards” on art.2 (36), as a mechanism to incentivize mortgages lenders to improve the energy performance of their building portfolio and “encourage” potential borrowers to make their properties more energy performing, is not clear and seems not to be applicable.
ABI - Associazione Bancaria Italiana
Industry association · Italy
Counts here are a floor, never a total: they cover the 639 consultation files tracked so far (53,766 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
ABI - Associazione Bancaria Italiana filed 2 positions between 1 Sept 2021 and 14 Feb 2022, across 2 of the 639 legislative files tracked here, attaching a full position paper 2 times.
What they argued
The proposal for a revision of the CCD does not take into account the significant digital evolution in recent years, the increasing use of digital devices and requests for simplification on advertisements, the rules of which would remain largely unchanged.
Filed in Italian · English published by the European Commission
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
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