Daisy chain of internal MREL

The “daisy chain” deduction framework increases the necessity of legal certainty, predictability, and proportionality in the internal MREL (iMREL) regulation.

Resolution groups with entities in only one member state should be exempted from the “daisy chain” deduction framework. The transitional period for applying the requirements should also be extended to 1 January 2024. Moreover, ESBG warns that the introduction of the “daisy chain” proposed by the European Commission in late October should explicitly not increase other prudential requirements for banks. Finally, the scope of application of iMREL should be fixed at 5% of Total Risk Exposure Amount (TREA) for non-resolution entities in the level 1 text and not left at the discretion of the Single Resolution Board (SRB) as is currently the case.

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Dominique Goursolle

ESBG elects Dominique Goursolle-Nouhaud as new president

The first woman president of the European Savings and Retail Banking Group (ESBG) is Dominique Goursolle-Nouhaud, president of the National Federation of French Savings Banks. She was elected today by the ESBG General Assembly for a period ending in 2024.

Dominique Goursolle-Nouhaud was elected today as president of the European Savings and Retail Banking Group (ESBG) for a three-year term. She is the first woman to occupy the position. She succeeds Helmut Schleweis, president of the German Savings Banks Association.

Together with ESBG members, Dominique Goursolle-Nouhaud will represent the specific model of savings banks, cooperative and retail banks at the European level. She is committed to showcase the social and economic contributions of the ESBG members to their communities.

She is committed to ensure that the specificities of the business model of the ESBG members are considered by EU policymakers. With ESBG, she will stand for a proportional application of regulation and supervision.

“We must defend the added value of our model”, said Dominique Goursolle-Nouhaud as she was elected. “Our strength today is to remain united to rise to the challenges of tomorrow. Let’s be stronger together”.

The members of the ESBG president committee are:

Isidro Fainé, president of CECA (Confederación Española de Cajas de Ahorros);
Helmut Schleweis, president of the German Savings Banks Association (Deutscher Sparkassen- und Giroverband);
Jens Henriksson, president and CEO of Swedbank;
Gabriele Semmelrock-Werzer, president of the Austrian Savings Banks Association (Österreichischer Sparkassenverband); and
Gerhard Brandstätter, Chairman of Cassa di Risparmio di Bolzano SpA.

About the National Federation of French Savings Banks

The National Federation of French Savings Banks (Fédération nationale des Caisses d’Epargne) is the body that represents 15 savings banks and regional cooperative banks, as well as their 4.5 million members and 2,600 elected representatives. Its main missions are to coordinate and strengthen the relation between the savings banks and their members/customers; to represent their common interests, in particular towards the public authorities; to support and train the elected representatives of the members; to define, coordinate and promote the social and environmental responsibility actions of the savings banks.

About ESBG

The European Savings and Retail Banking Group (ESBG) has 23 members in 18 countries. As some of its members are national organisations, ESBG represents the interests of over 800 banks working responsibly and closely with their communities and SMEs. Together, ESBG members manage assets worth €5,700 billion, serve 162 million Europeans and employ nearly 660,000 people.

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Call for evidence on the European Commission mandate regarding the PRIIPs Regulation

In Europe there are many PRIIPs that retail investors can purchase. In the area of structured products (PRIPs) alone, there are more than 1.5 million of them.

Regarding the use of the Key Information Documents (KIDs) to choose or compare between the products that banks offer to their clients, we believe that they do not play a role in product selection per se; there are other sources of information and the KIDs, which are designed for retail investors, are not suitable as a basis for product comparisons by the sales offices. For product approval purposes, the sales offices have designed separate technical solutions to obtain the required information. These tools allow, for example, the filtering of products according to certain product designs such as capital protection or certain underlings. However, there are individual contents of the KIDs that are used by the institutions for product selection. This includes, for example, the SRI, which is also used for the target market under MiFID II product governance.

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ESMA's review of the MiFID II best execution reports

The RTSs 27 (and 28) currently regulates the best execution reporting by execution venues and investment firms.

We understand that the crucial question for RTS 27 reports is if these reports should be re-instated. Based on the evidence we have with these reports so far, we do not think that they provide meaningful information which justifies the efforts of producing these reports. Neither have these reports been widely used by prospective recipients so far (measured by observed page views) nor are they helpful for investment firm’s own decisions to determine suitable best execution venues. We do not expect that the proposed modifications of RTS 27 reports would change that. Therefore, we welcome the European Commissions’s proposal to delete the Art. 27 (3) [RTS 27] as part of the Capital Markets Union package.

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Joint declaration on remote work and new technologies

On 7 December 2021, the European Banking Social Partners signed a Joint Declaration on Remote Work and New Technologies. The spread of the Covid-19 pandemic and the constantly increasing use of digitalised systems and processes led the Social Partners to reassess and appropriately update our approach to remote work in the European Banking sector.

In adaptable pattern of remote work, which allows for both higher productivity and an improved work-life balance, is a key aspect of the current and future ways of working. Therefore, UNI Europa Finance together with the EBF’s Banking Committee for European Social Affairs (EBF-BCESA), the European Savings and Retail Banking Group (ESBG) and the European Association of Co-operative Banks (EACB), worked together to ensure that employees’ and employers’ interests are safeguarded in these continuously changing working environments.

UNI Europa Finance President Michael Budolfsen said: “With remote work increasing at a rapid pace during Covid and beyond, it is opportune for the European Social Partners to come together to ensure this new way of working will stimulate a good work-life balance and not have a negative impact on the sector and its workers”.

UNI Europa Finance Director Maureen Hick added: “UNI Europa Finance welcomes the signing of this Joint Declaration and the commitment made today that remote work will not lead to any significant changes to bank employees’ rights and conditions and should be a topic of collective bargaining at all levels”.

Jens Thau, Chairman of EBF-BCESA, pointed out: “Banks and its employees have a strong track record of embracing new developments and putting them to work for their clients. The new Joint Declaration underscores the social partners’ commitment to responsibly shape this process of transformation.”

Michael Kammas, Vice-Chairman of EBF-BCESA highlighted: “The expertise of the Social Partners is pivotal when it comes to address new ways of working. This new Joint Declaration not only comes in the most appropriate time due to the pandemic and the continuous technological advancement, but it also shows the Social Partners’ ability to work together and agree on common approach encompassing all the significant aspects of Remote Work to ensure banks’ competitiveness and adaptability to the digitalized world of work.”

Peter Simon, Managing Director said for ESBG: “The Social Partners continuously strive for stable working conditions in accordance with the greater working situation. The Covid-19 crisis has escalated the need to establish good teleworking practices and adapt many roles to remote work. This Joint Declaration strengthens our commitment to employees to provide a secure environment”.

Nina Schindler, CEO of EACB explained: “The Social Partners’ agreement on the Joint Declaration on Remote Work is an effective and timely response to changes in working conditions. By signing this Joint Declaration, we demonstrate as the EACB our intent to safeguard the interests of European co-operative banks’ employees.”

The Social Partners have always proactively engaged with the effects of digitalisation. This new Joint Declaration builds on our previous commitments on Telework (2017) and on the Impact of Digitalisation on Employment (2018) by focusing on remote work as a specific type of adaptation to the way of working in the digitalised era. Understanding, shaping and keeping up with technological developments are very much at the heart of the European Social Partners’ approach in order to contribute to a strong and resilient banking industry.

To this end, the Social Partners have agreed to a common understanding regarding key aspects of remote work. These include collective trade union rights, health and safety, work-life balance, working hours and the right to disconnect, digital rights, resource and equipment costs, and access to training and career development.

This Joint Declaration on Remote Work and New Technologies is another significant achievement for the European Banking Social Partners, showing our continued commitment to engage together in current issues of common interest and adding our unique knowledge and contribution to the general debate on digitalisation.

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