We appreciate that the Commission understands the importance of competitiveness and proportionality for the European banking industry and acknowledges the room for improvement in many areas. Regarding the Commission's proposals, we highlight the following concerns (also see our attachment for further details): A dedicated and proportionate regulatory framework is needed for non-systemic institutions with low-risk…
NAG
National Association of German Cooperative Banks (BVR)
Industry association · Germany · EU Transparency Register 22330076571-75
6
positions filed
in the 665 files tracked
6
legislative files
of 665 tracked
5
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1519 trade and business associations on this site, they rank #589 by legislative files engaged, a count of participation, not a measure of influence.
12.9
declared lobbying FTE
self-declared
€2.8M+
declared costs / yr (floor)
2
EP accreditations
as declared to the register
2011
in the register since
Declares membership of
- Der Bundesverband der Deutschen Volksbanken und Raiffeisenbanken ist Mitglied bei folgenden Organisationen:
- Die Deutsche Kreditwirschaft (DK)
- Europäische Genossenschaftsbankenvereinigung (EACB)
- Internationale Genossenschaftsbankenvereinigung (CIBP)
- European payment council
- Netzwerk Europäische Bewegung Deutschland (EBD)
- Kangaroo Group
- International Raiffeisen Union (IRU)
- European Card Payment Cooperation (ECPC)
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- Bundesverband der Deutschen Volksbanken und Raiffeisenbanken (BVR)
- Head office
- Berlin, Germany
- EU office
- Brüssel
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
National Association of German Cooperative Banks (BVR) filed 6 positions between 8 Dec 2020 and 16 Sept 2026, across 6 of the 665 legislative files tracked here, attaching a full position paper 5 times.
2020 · 1 filed2021 · 1 filed2023 · 3 filed2026 · 1 filed
What they argued
The National Association of German Cooperative Banks (BVR e. V.) is the umbrella association of the cooperative banking sector in Germany. The “Volksbanken Raiffeisenbanken Cooperative Financial Network” (Genossenschaftliche FinanzGruppe Volksbanken Raiffeisenbanken) is the Cooperative Banking Group in Germany with currently (end of 2020) 814 individual small and medium regional oriented cooperative banks.
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.
Comment Feedback on the CMDI-review with a specific view on proposed amendments to the Deposit Guarantee Schemes Directive (DGSD) Contact: [name removed] Telephone: [phone removed] E-mail: [email removed] Berlin, 2023-08-25 Coordinator: National Association of German Cooperative Banks Schellingstraße 4 | 10785 Berlin | Germany Telephone: [phone removed] Telefax: [phone removed] https://www.bvr.de/de Page 2 of 6 The…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
BVR · Postfach 12 04 40 · 53046 Bonn European Commission Bundesverband der Deutschen Volksbanken und Raiffeisenbanken · BVR [address removed] Postfach 12 04 40 53046 Bonn Kontakt: Dr. [name removed] Telefon [phone removed] E-Mail [email removed] www.BVR.de Stellungnahme zur „Evaluation Roadmap/Inception Impact Assessment“ der Europäischen Kommission Der Bundesverband der Deutschen Volksbanken und Raiffeisenbanken…
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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.
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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.
Showing 5 of 27.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.