Position papers

  • EAPB Position Paper on the proposed Cross-Border Payments Regulation

    Payment services, Corporate governance and company law, Banking supervision 3 July 2018

    Generally speaking, the European Association of Public Banks (EAPB) welcomes the Commission’s proposed amendments to the Cross-Border Payments Regulation, which aim to strengthen fairness and increase consumer transparency. In particular, we share the opinion that transparency may be a decisive parameter in a functioning market. However, we believe that some aspects of this proposed Regulation may have substantial impact on the EU banking sector and we would therefore like to raise the following specific comments.

  • EAPB Comments on the Commission Proposal for a Regulation amending Regulation (EU) No 575/2013 as regards minimum loss coverage for non-performing exposures

    Banking supervision 11 June 2018

    In general, EAPB supports the intention of the "Action Plan" to reduce non-performing loans (NPLs). In order to ensure stability in the banking sector and to move towards the completion of the banking union, a reduction of NPLs seems necessary. Therefore, ensuring that financial institutions make sufficient provisions for loans that are non-performing is of importance. The Commission’s proposal of dealing with NPLs then is to create minimum coverage levels for newly originated loans that become non-performing. These will act as a statutory prudential backstop. For the EAPB however, the creation of a minimum level that is fixed for all institutions, independent of risk and independent of the amount of NPLs seems excessive.

  • Final EAPB response to the EC public consultation on the possible review of the SME definition

    Development, State aid 3 May 2018

    The European Association of Public Banks, EAPB, welcomes the possibility to provide feedback on the possible revision of the EU SME Definition as provided in the Recommendation 2003/361/EC. Generally EAPB believes that the small and medium-sized enterprises (SME) Definition has proven its worth in identifying those enterprises which are confronted with market failures particularly in the area of access to finance. As National and Regional Promotional Banks and institutions (NPB) EAPB members perform a public mission of fostering economic development, especially by contributing to SMEs growth. Thus, it supports any initiative from the European Commission to create favorable framework conditions for SMEs. SMEs form the backbone of the European economy. They are indispensable for growth, employment and innovation in the EU. Economies with a
    stable medium-sized base are evidently developing better.

  • EAPB position on exploratory consultation on the finalisation of Basel III

    Banking supervision 20 April 2018

    In the aftermath of the financial crisis, regulation has become not only more intensive and extensive, but also more complex. Standards of the Basel committee are intended for, and tailored to, large, complex, and internationally active financial
    institutions. As a result, the rules themselves have become large and extremely complex, and the “Finalization of Basel III” (Basel IV) is no exception.

  • Position paper on draft Commission Regulation amending Regulation (EU) No 1408/2013

    Development, State aid 12 April 2018

    EAPB position on draft Commission Regulation amending Regulation (EU) No 1408/2013 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid in the agriculture sector. The EAPB welcomes the opportunity to provide comments on the proposed draft amending regulation to the de minimis regulation for the agricultural sector. The EAPB highly appreciates that the Commission intends to increase the thresholds for aid in this key sector. Other proposals in the amendment, however, would make the granting of de-minimis aid very complex or even practically impossible for national and regional promotional banks.

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