FSB全球金融稳定委员会-Feedback-on-the-effects-of-financial-regulatory-reforms-on-SME-financing_3页_271kb

AMAFI Summary on FSB Consultation: Effects of Financial Regulatory Reforms on SMEs Financing

Core Content

The Association française des marchés financiers (AMAFI) has responded to the FSB consultation on the effects of financial regulatory reforms on SMEs financing. As a representative body for financial market participants in France, AMAFI includes credit institutions, investment firms, and trading infrastructures, both domestic and international. The organization emphasizes the importance of considering SMEs financing from a financial market perspective, alongside traditional banking approaches, given the growing role of markets in providing capital to SMEs.

Main Views

AMAFI believes that the current financial regulatory framework in the EU, particularly post-crisis reforms, has increased constraints on bank financing, thereby shifting the responsibility of SMEs financing to financial markets. They highlight the following key points:

• Diverse SME Definitions: The definition of SMEs varies across jurisdictions and between banking and financial market perspectives. From a financial market standpoint, SMEs are often defined by market capitalization, typically below 3 billion euros.
• Securitization Challenges: The STS Securitisation Regulation, which came into force in 2018, has not met expectations due to excessive prudential requirements and lack of ambition. The absence of Government Sponsored Enterprises (GSEs) in the EU hampers the development of securitization markets, unlike in the US where GSEs significantly support SME financing.
• MiFID II Impact: MiFID II, especially Article 13 of the Commission Delegated Directive (EU) 2017/593, has altered the economic model of financial analysis, making it harder for SMEs to access research and information. This could lead to a reduction in research supply, affecting the attractiveness and liquidity of SMEs.
• PRIIPs Constraints: Certain provisions under PRIIPs have made the sale of financial products more costly and complex, negatively impacting SMEs financing.
• Need for Market Simplification: The SME growth markets legislation aims to simplify regulatory requirements and improve SMEs' access to capital. AMAFI supports these changes and believes they should reduce costs and improve liquidity.

Key Information

• CMU Progress: The Capital Markets Union (CMU) initiative is still in progress, with limited legislation implemented so far, and some not yielding the desired outcomes.
• Taxation on Savings: AMAFI advocates for the reform and harmonization of taxation on savings to encourage long-term and riskier investments in SMEs.
• Alternative Financing: The development of alternative financing sources, such as Initial Coin Offerings (ICOs), is seen as a promising avenue. AMAFI has formed a working group to contribute to the regulation of such instruments.
• Innovation and Protection: While new technologies can reduce costs in financial markets, risks like money laundering, fraud, and market abuse are inherent and may be more pronounced. Therefore, it is crucial to balance innovation with investor protection.

Conclusion

AMAFI underscores the need for a more supportive regulatory environment that encourages market participation and reduces barriers for SMEs. They call for reforms in taxation, the creation of GSE-like entities, and the development of alternative financing mechanisms. These measures are essential to ensure the continued attractiveness and liquidity of SMEs in financial markets, especially as the EU faces challenges in its financial regulatory landscape and the UK's departure from the EU.