Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
What each said, in their own words
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
The European transposition of the Dec. 2017 Basel Accord is not merely an issue of banking supervision, but also one of the key issues in defending the sovereignty and competitiveness of the European economy. Banks have significantly increased their financial stability over the last decade (the solvency ratio of French banks, for example, improved from 5.8% to 13.8% between 2008 and 2017).
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 French Banking Federation (FBF) welcomes the proposal of the European Commission for the review of the Capital Requirements Regulation and Directive in the context of the Banking Package. The proposal is not yet in line with the mandate given by the G20, the Council and the European Parliament to the Basel Committee not to lead to a significant increase in capital for all banking communities.
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 Fédération Bancaire Française (FBF), as the spokesperson of the French banking sector representing the interests of more than 300 banks operating in France, including large and small, wholesale and retail financial institutions, local and cross-border, welcomes the opportunity to comment on the public consultation on FASTER Directive 2023/0187 on faster and safer withholding tax relief and to provide its…
Filed in French · English published by the European Commission
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.
The French Banking Federation strongly supports the proposal of the EC to reduce uncertainty in European financial markets through a Level 1 modification to the Benchmark Regulation, allowing the Commission to designate replacement rates for contracts that do not contain suitable fallback clauses. We welcome the opportunity to express our recommendations, which aim at supporting financial stability.
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