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EAPB Responses to the CEBS Questionnaire on Options and National Discretions

Overview

The European Association of Public Banks (EAPB) represents 27 public banks, funding agencies, and associations across Europe, collectively encompassing approximately 100 public financial institutions. These institutions manage a combined balance sheet of around EUR 3,500 billion and employ about 190,000 people, representing a European market share of approximately 15%.

Core Content

The EAPB has responded to the CEBS questionnaire regarding options and national discretions in the Capital Requirements Directive (CRD). This response was contributed in collaboration with the European Banking Industry Committee (EBIC), reflecting a common industry view. The EAPB has reached a consensus among various banking associations on a significant number of provisions.

Main Views and Key Information

• Importance of National Discretions and Options:
  The EAPB emphasizes that the issue of national discretions and options in the CRD is critical for its members. They acknowledge the efforts of CEBS and the European Commission to reduce these discretions to promote convergence and a level-playing field in the European banking sector.

• Need for Balanced Amendments:
  The EAPB urges CEBS and the Commission to consider any amendments to the current framework in a balanced manner. They highlight that banks have already implemented or are in the process of implementing the CRD, and any changes could result in substantial additional adaptation costs.

• Recommendation for Transformation into General Rules:
  For many of the options and national discretions, the EAPB suggests that they should be transformed into general rules rather than removed from the CRD. This approach is believed to support the broader objective of enhancing convergence and ensuring a fair competitive environment.

• Appreciation for Industry Consultation:
  The EAPB expresses appreciation for CEBS involving the industry in discussions and for the consultation process. They stress the importance of maintaining close contact with the industry when identifying potential changes to the current regulatory framework.

• Consolidated Responses:
  For areas where agreement within EBIC could not be reached, the EAPB has submitted consolidated responses from its members. This ensures a unified stance from the public banking sector in the face of regulatory changes.

Conclusion

The EAPB believes that the transformation of national discretions and options into general rules will be more beneficial for convergence and a level-playing field than their complete removal. They encourage CEBS and the European Commission to proceed with caution and to continue engaging with the industry in the development of regulatory changes. The EAPB is committed to providing a unified response and remains open to further dialogue and consultation.