European Mortgage Federation-European Covered Bond Council

The European Mortgage Federation-European Covered Bond Council (EMF-ECBC) welcomes the opportunity to provide its feedback to the European Commissions Call for Evidence in the context of the Review of the EU Taxonomy Environmental Delegated Act. Please find attached our full position.

The EU’s mortgage and covered bond industries will be instrumental in helping the EU meet its ambitious renovation targets and are fully committed to mobilising private finance to support the Renovation Wave and NextGenerationEU. Mortgages are crucial in securing an affordable socio-economic lift and incentivising the shift of critical volumes to support the climate transition.

New construction: The application of the SCC to buildings larger than 1000m² would result in a significantly larger number of residential buildings falling within scope. Additionally, all properties should immediately align with the ZEB standard and be subject to a GWP analysis, massively restricting applicability.

A competitive EU banking sector is essential to delivering the Competitiveness Compass and Affordable Housing agenda, enabling banks to mobilise financing for households, businesses and the wider economy. -Completion of SIU: Completion of the SIU requires strong and complementary banking and capital markets.

Mortgage lending represents nearly 9 trillion in outstanding loans , close to 50% of EU GDP, and remains the primary source of financing for homeownership in Europe. By enabling affordable and sustainable homeownership, mortgage markets improve social conditions and provide stability at the household level. They encourage investment and foster job creation and are major drivers of the EU economy.

The EMF-ECBC recognises the strategic importance of the Open Finance Framework and welcomes the opportunity to comment on the European Commissions Proposal for a Regulation on a Framework for Financial Data Access (FIDA), which is expected to have far-reaching implications for the banking industry and therefore the mortgage industry.

EU mortgage markets are fundamental to the economy. They provide access to finance for citizens to buy homes and for SMEs, stimulating investment and job creation. They will be vital to the post-pandemic recovery in many countries and the climate transition.

We are pleased to comment on the Proposal for a Revised CCD and to provide the following insights, which take account of the changing business environment and draw on our experience regarding implementation of the MCD.

European Mortgage Federation-European Covered Bond Council (EMF-ECBC) Response. The EMF-ECBC is a pioneer in energy efficiency financing, having launched the Energy Efficiency Mortgages Initiative (EEMI) in 2015.

We welcome the opportunity to comment on the EU Green Bond Standard (EuGBs). Covered bonds are mostly backed by mortgages on real estate and are essential to put the EU’s building stock on a net-zero emissions pathway. It is important to ensure that the EU Taxonomy works in practice and can be applied to EU covered bond markets, especially considering the long-term nature of mortgages.

The EMF-ECBC is pleased to provide the following comments on the European Commission’s Proposal for a Directive amending the Consumer Rights Directive (CRD) and repealing the DMFSD. Despite our overall positive assessment, we believe it is worth highlighting the need to further clarify and reflect on some elements as follows: Scope: • The scope of the Directive is unclear and should be clarified.