European Association of Public Banks

The EAPB fully supports the EUs objective of strengthening cybersecurity and digital operational resilience. However, overlapping and partly inconsistent reporting frameworks risk undermining both efficiency and security. Multiple, parallel reporting obligations lead to unnecessary complexity, administrative burden, and, in some cases, conflicting compliance requirements.

The European Association of Public Banks and Funding Agencies (EAPB) would like to highlight that National and Regional Promotional Banks and Institutions (NPBIs) are the place-based instrument the strategy is looking for. National and regional promotional banks combine a public-policy mandate, deep territorial knowledge and the capacity to assemble EU resources, national grants and private capital.

The European Association of Public Banks (EAPB) acknowledges the intention to preserve the open architecture of the InvestEU programme, which has proven valuable in mobilising investment through its implementing partners, many of which are National Promotional Banks (NPBs).

Our members public and promotional banks across Europe are strongly committed to high-quality, comparable and decision-useful sustainability reporting. The present response sets out our overall position on the Commission's draft, together with detailed comments on specific Disclosure Requirements (DRs) where further clarification or adjustment would, in our view, materially improve the operability and usefulness of…

Register ID: 8754829960-32 Re: POSITION on the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 Committee on Economic and Monetary Affairs EAPB position, 25.05.2022 The EAPB Secretariat would like to take the opportunity to comment on the Proposal for a Directive of the European Parliament and of the Council on…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The EAPB supports the planned transformation to a sustainable economy in Europe. The legislative proposal for a “Corporate Sustainability Reporting Directive” is an important step towards harmonised sustainability reporting. New reporting requirements seem to be rather ambitious, in terms of both content and timing. This applies especially to those companies and banks, which should report for the first time.

The European Association of Public Banks and Funding Agencies (EAPB) represents national and regional promotional banks across the EU. Our members design and deliver concessional lending for affordable housing, channel EU and national grants, and bring together public and private capital. This response is based on the direct operational experience of members active in the financing of affordable housing.

Please find attached, and also linked below, the EAPB's position paper on Housing Simplification and Finance. It identifies the EU legislation that National Promotional Banks and Institutions (NPBIs), the leading public financiers of social and affordable housing in Europe, consider most relevant, and sets out a number of proposals for improvement. https://eapb.eu/component/attachments/attachments.html?id=3829

EAPB supports the Communications overall ambition: a simpler, more proportionate and more competitive banking framework that continues to safeguard resilience. 1. What EAPB welcomes Proportionality as a core objective.

We welcome the European Commissions initiative to review the EU banking framework in a holistic manner and its objective to enhance competitiveness while safeguarding financial stability. In particular, we support ongoing efforts to simplify and streamline the regulatory framework.

We strongly support the objective of ATAD of combatting tax evasion and international tax planning. However, the negative impact the directive has on strategic investments and the one-size-fits-all character of certain exemptions may have led to a situation where the disadvantages of the directive outweigh the advantages for certain categories of entities that were never its intended target.

The EAPB welcomes the opportunity to offer evidence on the current programming period, followed by considerations for the post-2027 debate. Please find attached, as a good collection of examples of best practices delivered by EAPB members on the ground, our EAPB Compendium of Financial Instruments. I. Evidence from the 20212027 period 1. NPBIs are the logical delivery channel of cohesion investment.

We welcome the proposed measures that limit the negative effects of the regulatory framework on bank’s capital requirement and thus on the real economy (e.g., the retention of specific treatments, the implementation periods and the relief for banks when calculating the output floor (OF)). In the upcoming legislative process, it is essential not to dilute these measures - where they are risk-adequate.

The Regulation, as proposed, is a step in the right direction in regulating the ESG ratings market and improve the quality of ratings but issues remain. We welcome that more transparency and reliability is being brought into the procedures regarding methodologies.

European promotional banks carry out targeted promotional measures on behalf of their owners central and regional governments and municipalities. National, regional, and often additional European funding is used for this purpose. European state aid rules are of essential importance in this context.

The European Association of Public Banks (EAPB) would like to highlight the importance of adapting performance monitoring frameworks to better reflect the specific role and mission of public promotional banks. In that sense, evaluations should not be limited to financial absorption or return, but also consider developmental impact, social value, and the sustainability of investments.

The idea of a central contact point for relevant information is understandable. However, due to the large volume of information, it can easily become confusing and not useful for market participants. Duplicate reporting or publication channels should be avoided but built on existing systems. The start date for ESAP is very ambitious.

Please see attached file for more extensive comments. We particularly welcome the Commission’s proposal that so-called mandatory buy-ins pursuant to Article 7 of the CSDR should not initially apply. The buy-in is an instrument intended to protect the buyer and therefore belongs at trading level.

Summary of the EAPB position (the full position paper is attached) The EAPB welcomes that the Commission has proposed a voluntary EuGB label rather than a binding one. However, the draft regulation falls short in several crucial respects that, if not addressed, would cause significant problems for both investors and issuers (bond-by-bond issuers as well as issuers who apply a portfolio approach, where a pool of…

The initiative is well-timed and addresses a real need in the market. For venture and growth capital to play their proper role in supporting European competitiveness, the regulatory framework must enable fund managers to grow and operate at European scale without facing disproportionate burdens or structural obstacles.

EAPB wishes to comment on the following aspects: 1. Active accounts-requirement - new Art. 7a EMIR a) Design, calibration, implementation of active accounts-requirement b) Material scope c) Timelines 2. Exposure reduction planning and target setting obligation for institutions - Art. 76(2) CRD/Art. 29(1) IFD and corresponding new supervisory exposure reduction enforcement power - Art. 104(1)(n) CRD/Art.

We suggest that national promotional banks be considered as eligible implementing partners for EU-supported investments in resilience, preparedness and civil protection infrastructure at national and regional levels.

The EAPB supports the objectives of the CMDI review which aims at strengthening rules for handling bank failures while protecting depositors. It is important however that the review duly considers the business model of promotional banks and other public banks which primarily fund the public sector and SMEs.

The Guarantee Notice is an important legal basis for the activities of national and regional promotional banks and funding agencies, represented by EAPB. We would like to share several proposals to prevent divergent interpretations across Member States and reduce unnecessary administrative workload for beneficiaries.

We appreciate the opportunity to provide feedback on the 'Targeted revision of the financial rules applicable to the general budget of the EU (i.e. the Financial Regulation)'. Please find herewith attached the response from the European Association of Public Banks (EAPB). Kind regards