Compare organizations

Mutual Funds and, more recently, semi-transparent ETPs employ limited or delayed reporting of their holdings to protect their IP. With the plan to introduce a monthly look-through requirement, proposed under 325j(1)(a), what is the expectation for banks to calculate capital requirements for these kinds of instruments?

The Banking Package should strike the right balance between meeting the fundamentals of the Basel Committee reform, keeping the capital requirements for banks without any significant increase as mandated by the G20 and reiterated by the European Parliament and the European Council and, also, observing key European specificities.

The European Banking Federation (EBF) welcomes the intention of the European Commission, in the context of the Banking Package, to also bring more clarity to some aspects related to resolution. However, after an initial analysis of the draft text, we are of the opinion that some technical aspects, described in more detail in the file attached, would deserve additional consideration.

IHS Markit greatly appreciates the opportunity to comment on the “New EU System For The Avoidance of Double Taxation and Prevention of Tax Abuse In The Field of Withholding Taxes”. Our comments in support of this initiative have been submitted via a separate document. We look forward to working with you on this initiative.

The EBF welcomes efforts at simplification and digitisation of withholding tax processes within the Union. Slow and complex withholding tax reclaim processes remain barriers to efficient investment. A simple, swift, and safe system would encourage intra-union and foreign investment. Nevertheless, the proposed rules remain complex and would require significant due diligence and reporting.

IHS Markit is a leading benchmark administrator. IHS Markit Benchmark Administration Ltd. (IMBA UK) has been FCA authorised since July 2017, and Markit N.V. (IMBA EU) received AFM authorisation in December 2019. These administrators provide more than 29,000 benchmarks across financial, economic and commodity underlyings, including proprietary benchmarks and benchmarks administered for clients.

We welcome the European Commission’s decision to provide for the possibility to designate one or more statutory replacement rate for benchmarks, whose cessation would result in a significant disruption in the functioning of financial markets in the Union (BMR statutory replacement).