German Savings Banks Association (DSGV)

DSGV welcomes the Right to Stay initiative: Strong regions need strong regional financing structures The European Commissions initiative Right to Stay Your Region, Your Future addresses a key challenge for Europes future: How can economic strength and social cohesion be secured across all European regions? DSGV strongly supports the objective of strong regions. The initiative is closely linked to Art.

The German Savings Banks Association (DSGV) welcomes the Commissions objective of reducing unnecessary regulatory and administrative barriers to housing construction and renovation. Simplification should reduce costs and delays while preserving financial stability and balancing safety, quality and climate resilience.

"The German Savings Banks Association welcomes the European Commissions initiative to strengthen the competitiveness of the European banking sector and the Single Market and to review the supervisory and regulatory framework. Europe needs to finance substantial investment in the green and digital transformation as well as in strengthening its geopolitical resilience.

The German Savings Banks Association (DSGV) welcomes the European Commissions Call for Evidence on the competitiveness of the Single Banking Market. In our view, the competitiveness of the EU banking sector should be assessed not only by reference to size, cross-border consolidation or capital market footprint, but also by banks ability to finance households, SMEs, municipalities and long-term transformation needs…

The German Savings Banks Association supports the intention of the European legislator to use the Retail Investment Strategy (RIS) to make investment processes more client-friendly and thus to strengthen the participation of retail investors in the capital markets. In particular, we wel-come the (temporary) refraining from a complete ban on inducements.

BRRD Public Interest (Art. 32 (5) in conjunction with Art. 31(2) and Art. 2(1) No. 35 BRRD draft) The proposed approach of making resolution the standard for crisis management in the banking sector is foreseeably more bureaucratic and financially burdensome, especially in the case of small and medium-sized institutions.

In addition to technical changes, the adjustments in the DGSD within the framework of the CMDI review primarily focus on preventive (including institutional protection) measures. Without merit, the EU-COM is thus shifting the focus of the DGSD review to market structures of networks of small and medium-sized regionally institutions. The newly formulated requirements for preventive measures are materially very high.

SRMR The German Savings Banks Association remains critical of the view of the SRB and the EU Commission that the target level of the SRF is to be understood as dynamic and should therefore be at least 1% of covered deposits at all times. Unfortunately, the CMDI-Review does not contain any adjustments in this respect.