EBA欧洲银行-CP38_UCG_2页_154kb

UniCredit Group's Reply to CEBS CP 38 on Article 106(2)(c) and (d) of Directive 2006/48/EC

General Remarks

UniCredit Group (UCG) experts have reviewed the proposed guidelines by the Committee of European Banking Supervisors (CEBS) related to Article 106(2)(c) and (d) of Directive 2006/48/EC, as recast. They expressed general comfort with the CEBS proposal and its feasibility for implementation within the Group.

However, the UCG team suggested a few clarifications to better understand the scope of the guidelines, particularly regarding the definition of "client typology" in the context of transactions.

Key Clarifications Requested

• Scope of Transactions: It is recommended to clarify whether the term "transactions" in the guidelines refers exclusively to external clients or also includes intra-group transactions.
• Client Segmentation: If transactions are limited to external clients, there should be further explanation on whether the focus is on all client types or specific segments.

These clarifications are important to ensure a consistent and accurate interpretation of the guidelines across the Group's operations.

Contact Persons

Area Heads

• Gabriele Stinco – Strategic Risk Management And Control (SRMC)
  Email: Gabriele.stinco@unicreditgroup.eu

• Juergen Kullnigg – Corporate Investment Banking Credit Risk (CIB&CR)
  Email: Juergen.Kullnigg@unicreditgroup.eu

• Sergio Lugaresi – Regulatory Affairs (RA)
  Email: Sergio.Lugaresi@unicreditgroup.eu

CEBS Contact

• Marco Laganà – Regulatory Affairs (RA)
  Email: Marco.Laganà@unicreditgroup.eu

Group Finance

• Mara Milani – Coordinator, Group Finance (GF)
  Email: Mara.Milani@unicreditgroup.eu

• Pier Mario Satta – Head of Group Treasury (GT)
  Email: PierMario.Satta@unicreditgroup.eu

• Mirco Brisighelli – Head of Settlement & Liquidity Risk Management, GT
  Email: mirco.brisighell@unicreditgroup.eu

• Paolo Cristiano Allegri – Head of Financial Planning, ALM&FP
  Email: PaoloCristiano.Alegri@unicreditgroup.eu

Strategic Risk Management And Control

• Valeria De Mori – Coordinator, SRMC
  Email: Valeria.DeMori@unicreditgroup.eu

• Antonella Cozzi – Banks and Financial Institutions, CIB&CR
  Email: Antonella.cozzi@unicreditgroup.eu

• Inge Susanne Luppold-Raff – Head of Group Risk Policies, SRMC
  Email: IngeSusanne.Luppold-Raff@unicreditgroup.eu

• Andrea Cappon – Group Risk Policies, SRMC
  Email: andrea.cappon@unicreditgroup.eu

Summary of Core Content

UniCredit Group's response to CEBS CP 38 outlines their positive stance on the proposed implementation guidelines for Article 106(2)(c) and (d) of Directive 2006/48/EC. The Group acknowledges the CEBS proposal and believes it is implementable. However, they highlight the need for further clarity on the definition of "client typology" in the context of transactions, specifically whether the scope includes intra-group transactions or is limited to external clients, and whether the focus is on all client types or specific segments.

The response is structured with input from various departments within the Group, including Regulatory Affairs, Strategic Risk Management and Control, and Group Finance, indicating a cross-functional approach to the review and feedback process. The contact persons listed are responsible for coordinating and providing insights from their respective areas.