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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 European Savings and Retail Banking Group (ESBG) positively assesses the banking package proposal issued by the European Commission. It transposes the final elements of the Basel III reforms in the EU regulatory framework and it pursues other prudential and supervisory objectives.

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.

European Savings and Retail Banking Group (ESBG) welcomes the opportunity to provide feedback to the European Commission's consultation on the "New EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes". ESBG is pleased to provide the comments in the attached document.

We agree with the EC that green bonds play an increasingly important role in asset finance and we expect that this trend will continue and increase in importance for fixed income investors. Recognising this increasing importance and the role data will play, firms such as IHS Markit are currently engaged in research and development activities around what bond level Green/ESG content could look like.

ESBG applauds the EU's efforts to develop a binding and consistent green bond standard that is linked to the EU Taxonomy. Below you may find some concerns with the current proposal: • The number of organizational requirements in the proposal (fifty provisions deal with the legal framework of external reviewers and other supervisory powers while only thirteen deal with the green bond itself ) exceed the purpose of…

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.

ESBG supports the Commission’s approach on a revision of the Benchmark Regulation (BMR). The main objective should be granting broader powers to competent authorities at national level or Europe-an to ensure an orderly cessation of a critical benchmark, these powers should include the mandate to continue granting the provision of a critical benchmark using a different methodology or a replacement rate.