BNY Mellon

BNY welcomes the European Commissions Communication on the competitiveness of the EU banking sector. BNY would like to highlight four points that BNY believes are insufficiently covered in the Communication. 1. We agree with the Commissions observation that many rules continue to apply irrespective of size or business models, resulting in unnecessary complexity and administrative burden for banks.

BNY welcomes the Market Integration Package (MIP) and its policy objectives of deepening the single market, reducing fragmentation, and unlocking cross-border efficiencies for savers, issuers and intermediaries.

BNY welcomes the Market Integration Package (MIP) and its policy objectives of deepening the single market, reducing fragmentation, and unlocking cross-border efficiencies for savers, issuers and intermediaries. BNY fully supports the proposals in the Master Directive that would allow depositary banks to provide depositary services for investment funds on a cross-border basis.

BNY welcomes the opportunity to respond to the European Commissions call for evidence in relation to a planned legislative initiative entitled Savings and Investments Union: Fostering integration, scale and efficient supervision in the single market.

In summary, we are concerned that MiFID-authorised asset managers are being brought into scope of the EU intermediate parent undertaking (EU IPU) requirements. Please refer to our submitted letter which has more detail, and drafting solutions. Our letter also comments on internal TLAC.

BNY Mellon welcomes the opportunity to give feedback on the FASTER Proposal. We support many elements of the Proposal, and believe that, if the Proposal is implemented, it will make a significant contribution to improving the attractiveness of European capital markets.

BNY Mellon supports the implementation of a standardized EU-wide system for withholding tax relief at source. We believe that that this is a necessary feature of a European Capital Markets Union. Accordingly, we support Policy Option 2. However, Policy Option 2 should be complemented by Policy Option 3, as any effective common system of relief at source will need to be founded on extensive exchanges of information.

BNY Mellon welcomes the CSDR REFIT Proposal adopted by the European Commission. We believe that the Proposal introduces important and necessary changes to CSDR. Yet we also believe that the Proposal has some gaps, and can be improved.

BNY Mellon welcomes the planned review of CSDR. We believe that CSDR has played an important role in the development of safe and efficient financial market infrastructure in Europe, and that there is scope to modify CSDR in order for the objectives of CSDR to be met in a more effective and efficient manner.