Policy Advisor in CSR

The World saving and the Retail Banking Institute (WSBI) and the European Savings and Retail Banking Group (ESBG) is looking for a Policy Advisor in CSR.

With roots in 1924, WSBI-ESBG members enjoy a long history of socially responsible banking around the world.
Within this framework, WSBI-ESBG members attach a strong commitment to sustainable development and include Corporate Social Responsibility (CSR) as a fundamental and integrated part of their business recommending an engagement to responsible principles where financial inclusion and financial responsibility remain important opportunities and challenges, they each share certain values in their business models, embedded within the three “R”s.

RETAIL: Actively providing financial services for people – individual
consumers and their households – as well as for MSMEs and local authorities.
Financing the real economy;

REGIONAL: Deploy broad distribution networks rooted within the communities they serve,
including local and regional outreach in both urban and rural areas. Savings
mobilized locally support the local economy;

RESPONSIBLE: Social responsibility is a core value of our members, towards their clients,
employees, communities and the environment. Unlike Wall Street players, WSBI
members are Main Street players.

The WSBI-ESBG is recruiting a full-time policy advisor on corporate social
responsibility. He/she/d will be responsible for exploring and developing
policy positions and coordinating members’ actions in the field of Corporate
Social Responsibility (CSR); Particularly, he/she/d will also have to work
in the organisation of the CSR Committee, supporting the Chairperson and
members of the Committee.


• Advocating in the field of corporate social responsibility ;
• Supporting members implementing international and social affairs related regulations,
social responsibilities and social dialogue;
• Frame, organise and develop the CSR Committee, formerly the European Committee (ESBG),
into a truly global committee that includes our members worldwide (WSBI)
• Supporting the WSBI-ESBG Communication Department in developing strategic messages in
international, social affairs;
• Maintain and update WSBI-ESBG data base to collect case, studies on members’ CSR related activities including foundations work;
• Actively implementing direct contacts with the institutional policy makers such as the European Commission, the European Parliament the Council (Member States) and others international institutions;
• Develop a strategy on the field of financial education representing WSBI-ESBG with social partners in the contact of EU social dialogue project.


• Completed university degree in law, finance, economy, political science or similar;
• Some experience in advocacy work;
• Ideally, 2-3 year’s experience in banking/financial and investment services;
• Excellent organisational skills and capacity to prepare large meetings and events, setting out agendas, including overseeing the administrative work and taking responsibility on their development;
• Good political, strategic and technical understanding of the abovementioned topics;
• Profound understanding of the EU law-making environment and decision-making process;
• Excellent interpersonal and communication skills in a multi-cultural environment;
• Excellent influencing skills, persuasiveness and sense of diplomacy;
• Good interpersonal and personal bridge skills and ability to work under pressure;
• Enthusiasm and a positive attitude towards the various projects for which he/she/d will be responsible.
• Perfect command in English, other EU languages are an asset.

Interested candidates are invited to send a C.V. accompanied by a covering letter by email to hr@savings-banks.com before 31st OCTOBER 2023.

WSBI as a catalyst for unlocking the potential of female entrepreneurs

Month: September 2023

13 October 2023

9H30am - 12H00pm

Hôtel Du Golf Rotana Palmeraie

Marrakech, Morocco

400 million women entrepreneurs around the world who have vast potential to grow, add value to the economy and create jobs. Yet they face significant obstacles, including an uneven playing field in accessing financing. Closing financing gaps for women entrepreneurs would create $5-6 trillion in potential value addition globally. For financial service providers (FSPs) this represents a $1.7 trillion growth opportunity. This is an opportunity for banks, funds, fintechs, regulators, investors and standard-setting bodies worldwide to step up their efforts and work together to unlock their economic potential.

Leveraging on WSBI’s strategic goal of building inclusive and sustainable financial sectors, the Scale2Save initiative continues to engage sector players to assess, design and implement initiatives that help build resilience and sustainable solutions for the most vulnerable. Understanding the impact that the financial sector has on serving female entrepreneurs, the actions that lead to more gender equity and agreeing on common metrics that serve these goals forms part of these efforts.

Format: An interactive panel discussion between WSBI members from different regions of the Global South and a representative from a Development Financial Institution, will be followed by contributions from the floor. The session will be preceded by a keynote speech from the Women Entrepreneurs Finance Initiative, which is housed at the World Bank. Translation into English, French and Spanish will be available during the event.

Expected outcomes: This session aims at demonstrating the power of the WSBI network in serving female led and/or owned SMEs. It will highlight what member institutions from two or three regions are doing to empower female entrepreneurs, to help overcome the digital divide, to deploy adaptive solutions to a growing climate risk and to assure that women’s specific financial and non-financial needs are met. The session will also address how DFI financing support can contribute to higher impact with female entrepreneurs. The keynote will be setting the scene on what it takes to get a better understanding of how the financial sector impacts female entrepreneurs and generate a common understanding of the World Bank supported WE-Finance Code. The WSBI General Assembly that will follow in the afternoon is expected to endorse the WE-Finance Code Initiative.

Participants (50-80 pax): WSBI members from all regions, open to external guests (participants to the World Bank / IMF annual meetings).

The event is organized in the framework of the WSBI African Regional Group Meeting and General Assembly that take place 11-13 October alongside the annual World Bank /IMF meetings.

Wendy Teleki
Keynote Speaker
Head of the Women Entrepreneurs Finance Initiative (We-Fi) Secretariat, housed at the World Bank

Weselina Angelow
Senior Programme Director Scale2Save

After the keynote speech,we will have an interactive panel discussion with speakers from four different continents.

Cynthia Ikponmwosa
MD/CEO, LAPO Microfinance Bank Nigeria

Verónica Kunze
Vice-Chair, BancoEstado

Marie Agler
Chief Investment Officer (CIO)
Swedfund International, Sweden

Nasser Alkahtani
Executive Director, Arab Gulf Program for Development (AGFUND)
Saudi Arabia

Savings and Retail Banking in Africa 2022 WSBI survey of Financial Inclusion for micro, small and medium-sized enterprises (MSMEs)

The Savings and Retail Banking in Africa report aims to help improve access to financial services for financially

Read More

WSBI’s MD Peter Simon opens the G20 side event panel “Gender equity and SME financing in a digital landscape” at the SME Finance Forum in Mumbai

The World Savings Bank Institute (WSBI-ESBG), with the substantial support of its Indian member, the State Bank of India

Read More

Driving formal savings: What works for low-income women

Gender-inclusive products need to be designed with low-income women’s needs in mind. Yet, the real question remains: What services do female customers value, prioritize and need?

Read More

Applying a Gender Lens to Digital Transformation in Africa

Widespread use of mobile technology is driving digital access on the continent...

Read More

WSBI shares conclusions of its 6-year programme on financial inclusion

WSBI programme for financial inclusion shared its conclusions at a closing event in Paris, attended by financial stakeholders from four continents.

Read More

Scale2Save brings Ugandan financial stakeholders to commit to financial inclusion

A WSBI knowledge sharing event in Kampala ended with joint call to action for financial inclusion.

Read More

Scale2Save champions inclusive financial services for Nigerians

WSBI's programme held its first event in-person event since the pandemic in Lagos to great success.

Read More

WSBI's MD Peter Simon opens the G20 side event panel "Gender equity and SME financing in a digital landscape" at the SME Finance Forum in Mumbai

WSBI's Peter Simon opens the G20 side event panel "Gender equity and SME financing in a digital landscape" at the SME Finance Forum in Mumbay

The World Savings Bank Institute (WSBI-ESBG), with the substantial support of its Indian member, the State Bank of India, and in collaboration with the World Bank’s SME Finance Forum and the International Finance Corporation’s Women Entrepreneurs Finance Initiative (We-Fi), organized and hosted the WSBI’s G20 India Side Event & Reception on the 14th of September 2023. This event was officially recognized as part of the G20 side events under this year’s presidency in Mumbai.


In accordance with its long-term objectives and reflecting the urgent concerns of its 95 global members, the WSBI panel delved into the pivotal role the banking sector can assume to bolster women entrepreneurs. The panel, named “Gender equity and SME financing in a digital landscape,” was inaugurated by WSBI Managing Director, Peter Simon. Distinguished panellists included Wendy Teleki , Head of Women Entrepreneurs Finance Initiative (We-Fi) The World Bank, Saloni Narajan, Deputy Managing Director & COO of  State Bank of India, Colin Daley, Senior global Advisor from IFC – International Finance CorporationNina Fenton, Head of Regional Representation, South Asia  European Investment Bank (EIB) and Syel Abdul Momen, Deputy Managing Director & Head of SME BRAC Bank Limited.

Mr. Simon (WSBI) explained how women, especially those leading SMEs, face distinct challenges that must be addressed by the Savings and Retail Banks as key players in the financial sector.

Some of the hurdles that women face ranges from accessing finance, navigating intricate regulations, to balancing climate goals with immediate concerns like high energy expenses, inflation, and fluctuating commodity markets. Such challenges are even more pronounced for women led MSMEs, especially within financial systems dominated by banks.

Women-led SMEs (WMSMEs) remain underrepresented in the financial sector, representing a mere 28% of its clientele. This disparity was emphasized by Ms. Teleki, WeFi, who commended the WSBI’s dedication to address it.

The gap between financial need and availability is huge. Of the 8.9 trillion USD required for MSME finance, only 3.7 trillion USD is on offer, with WSMEs accounting for a stark 32% of this deficit. Barriers from both demand and supply sides exacerbate these disparities. According to Mr Memon, Brak Bank, solutions to those issues do exist, as BRAC’s experience and pioneering work in Bangladesh is showing.

The Women Entrepreneurs Finance Initiative (WEFI) led by the World Bank, estimates a staggering $5 trillion loss in global value due to this financial neglect.

WSBI in collaboration with the Mastercard Foundation, the WSBI’s Scale2Save Partnership, similarly points out the undervaluation, informality, and reduced job creation by female-owned enterprises. Mr. Daley (IFC), drawing from his extensive African experience, echoed these sentiments, spotlighting the necessity for more accessible funding avenues for female entrepreneurs.

On the other hand, OECD’s research highlights that women entrepreneurs in advanced economies face strikingly comparable hurdles. Ms. Fenton (EIB) expanded on this, discussing EIB’s initiatives in Europe, particularly their efforts to foster gender data availability.

Yet, there’s optimism for the future. As emphasized by Ms. Soloni (State Bank of India), digital financial services customized for women led MSMEs, coupled with universally acknowledged digital identities, could redefine financial inclusion.

Mr. Simon (WSBI) , explained how, given the absence of gender-specific data, it’s imperative for policymakers, the entire industry, and the banking sector for a better understanding of their female customers, to compile exhaustive gender-centric data and standardize definitions for women-driven businesses.

Peter Simon also stressed how banks are key to this transformative journey, and they need to address the following challenges:

  1. Cultivate gender sensitivity by building meaningful relationships with women clients. WSBI members are very well-positioned to do this under the well-respected 2X Criteria on leadership, staffing and market as it is shown on the WSBI’s members pilot data survey.
  2. Establish and monitor gender-focused targets by amplifying women’s credit access and evaluating progress through global benchmarks.
  3. Offer holistic non-financial services surrounding women with a spectrum of resources from financial assistance to mentorship.
  4. Utilize technology for enhanced services by modernizing data management and enriching customer experiences with state-of-the-art platforms.
  5. Adopt non-traditional collateral through facilitating women’s access to credit by recognizing diverse collateral forms.


In conclusion, the panel concluded there is a clear need to drive a transformative shift towards financial equity unleashing the potential of women entrepreneurs across the globe

Read Mr. Simon full speech

ESBG responds to the ECB consultation on its Guide to Internal Models

On 15 September 2023, ESBG responded to the European Central Bank (ECB) public consultation on its revised Guide to internal models. The Guide clarifies how banks should go about including material climate-related and environmental risks in their models. It also provides clarifications for banks that wish to revert to the standardised approach for calculating their risk-weighted assets. On credit risk, the guide helps all banks to move towards a common definition of default and a consistent treatment of massive disposals. The update of the market risk chapter details how to measure default risk in trading book positions. The Guide also provides clarifications regarding counterparty credit risk.

Generally speaking, the revised Guide is very prescriptive in relation to the documentation to be provided in the application for reversion to less sophisticated methods, but it does not explain how the ECB will make its assessment. More clarity would therefore be needed.

Among other technical points, ESBG stressed that in the event of a model change, it should be sufficient to provide the functional and technical implementation concepts including for systems testing as evidence for the ability to provide a new version of the relevant IT systems.

We consider the introduction of a new type of obligor as inconsistent with the currently applicable Article 147 CRR unless the concept of joint credit obligations (JCOs) is fully reflected in internal risk management practices. The added complexity seems redundant from a risk quantification perspective.

On model-related margin of conservatism (MoC), the requirements regarding internal model validation should not apply at the level of the third party-provider but only at the level of the individual rating model.

Moreover, due to an inconsistency with CRR, it is also necessary to clarify that the estimate credit conversion factor (CCF) should be computed as “default weighted average resulting from all observed defaults within the data sources”.

Finally, the implementation of an alternative days past due counter for any country not within the SSM responsibility would be a very high effort that does not justify the minor improvements in credit risk steering, A more flexible, potentially conservative, formulation could be found.

Looking ahead, ESBG will continue to closely monitor the ECB work on its revised Guide.

Executive SummaryFull Position Paper

Roberto Timpano
Principal Advisor-Prudential Policy and Supervision
e.: roberto.timpano@wsbi-esbg.org
t. : +32 2 211 11 66

ESBG’s new position paper on the digital euro highlights pivotal open issues to be addressed by the legislators

Following the publication of a proposal for a Regulation on the establishment of the digital euro on 28 June 2023, the European Commission launched a public call for feedback on the legislative proposal. Over the last weeks, ESBG members collected their considerations in a position paper on the Regulation which has been submitted to the European Commission on 8 September 2023. The paper highlights pivotal open issues that need to be addressed by the legislators in the upcoming debates.

Among others, ESBG members call for a qualified opinion of the European Court of Justice to clarify the legal basis of the proposed Regulation and recommend to carry out an impact assessment by a neutral party or the European Central Bank before introducing a digital euro to assess the consequences for financial institutions, market competition, and overall economic stability holistically.

In addition, ESBG members stress that initial individual holding limits should be capped at EUR 1,000, offering sufficient flexibility for daily transactions while maintaining financial stability. Building on this, the paper underlines to frame the digital euro as a means of payment rather than establishing a new payment scheme to leverage on existing infrastructure and foster innovation.
Overall, ESBG members outline that many questions on its technical implementation, legal basis, financial stability and market competition remain open and need to be addressed before issuing a digital euro.



Contact Info:
Astrid Satovich
Advisor- Payments, Aml & Digital Finance
e.: astrid.satovich@wsbi-esbg.org
t.: +32 2 211 11 36

ESBG advocates for further clarity and consistency in IFRS 9 Impairment requirements

On 13 September, ESBG responded to the European Financial Reporting Advisory Group’s (EFRAG) consultation on the Post-implementation Review of IFRS 9’s impairment requirements.

In its response, ESBG stated its alignment with EFRAG’s priority assessment, but emphasized the need for elevating the Purchased or Originated Credit-Impaired (POCI) topic to “high” priority. It also recommends addressing climate-related risks as a medium priority. Additionally, ESBG highlights other crucial topics, including recognizing expected credit losses, clarifying Significant Increase in Credit Risk (SICR), and refining methods for measuring expected credit losses through forward-looking scenarios and post-model adjustments.

One significant concern addressed by ESBG is the ongoing cost risks faced by financial entities due to regulatory interpretations of IFRS 9. The measurement of expected credit losses for Stage 1 financial assets, subject to individual assessments for significant credit risk increases, lacks clear guidance, leading to varying interpretations by regulators and enforcers. ESBG proposes clarifying the standard to explicitly allow collective loss calculations alongside individual assessments.

ESBG also delves into issues related to determining significant increases in credit risk (SICR). They note the lack of clarity in the concept, resulting in inconsistent interpretations. Additionally, the exemption based on assuming low credit risk at the reporting date is seen as operationally complex and suited only for extremely low probability of default cases. Proposed solutions involve clarifying SICR determination methods and aligning with Basel Committee on Banking Supervision standards.

Regarding measuring expected credit losses, ESBG highlights inconsistencies stemming from the lack of specific guidance. To address this, ESBG urges the IASB to provide additional application guidance, illustrative examples, and clear “bright lines” to ensure consistent use of forward-looking information.

The current accounting approach for POCI assets presents challenges, particularly for institutions where POCI assets are not central to their business model. These institutions face operational difficulties and resort to manual adjustments due to IT system limitations, leading to inconsistencies in practice. To resolve this, ESBG suggests allowing POCI assets to be classified in stages with transfers, implementing a gross-up approach for recognizing initial expected credit losses, and continuing stage 3 accounting for credit-impaired loans subject to restructuring, ensuring a more accurate reflection of management’s objectives.

Lastly, ESBG supports EFRAG’s assessment of lacking clarity and comparability in current credit risk disclosures. The proposed solution involves setting clear disclosure objectives, requiring judgment in compliance, and implementing entity-specific disclosure requirements.

Executive SummaryFull Position Paper

Contact Info:
Andreea Lungu
Advisor- Financial Reporting And Taxation
e.: andreea.lungu@wsbi-esbg.org
t. : +32 2 211 11 64

ESBG provides overall assessment on clients’ sustainability preferences under the current framework by replying to the ESMA’s Call for Evidence

On September 13, the ESBG submitted its response to the European Securities and Markets Authority (ESMA) Call for Evidence on the integration of sustainability preferences in the suitability assessment and product governance arrangements, which was launched on 16 June 2023.

It is worth to recall that this Call is not intended by ESMA to open a new consultation on the content of the suitability guidelines or of the guidelines on product governance. Indeed, ESMA, together with the national competent authorities, plans to monitor the application of the guidelines on suitability and on product governance by firms and will consider complementing them with Q&As and/or will make any necessary changes during the next review of the guidelines.

ESBG therefore provided qualitative and (where possible) quantitative elements, gathered by the savings banks around Europe, with the aim to provide the Authority with a better understanding on how MiFID II requirements have been implemented and applied by its members, as well as a concrete understanding of investor experiences with the incorporation of sustainability factors within the investment’s services and portfolio management.

In general terms, the followings have emerged:

• The savings banks’ employees are well trained on sustainability issues, specifically investment advisors, sales representatives, and client facing staff.
• The savings banks have extensive organizational procedures and measures in place to ensure that potential conflicts of interest do not affect customers’ interests, including their sustainability preferences. These measures apply to investment and ancillary services, including investment advice and financial portfolio management.
• The compensation structure does not create any incentives for employees’ decisions to be influenced positively or negatively by the inclusion of sustainability preferences in the provision of investment advice or financial portfolio management.
• There is a combination of means by which banks provide information about sustainable finance to their client (physical meetings, online channels, educational brochures, bank’s website, etc.). The combination of different methods/channels is quite effective.
• Even though clients show a general understanding of sustainability aspects and why sustainability is an important aspect of their lives, they – despite all the procedures and measures put in place – do not fully understand the small differences between the various sustainable product types specified by the law and the complex and very granular (legally prescribed) query.
• In general, the complexity of the EU-rules has the effect of making retail clients less interested in expressing sustainability preferences, which is counterproductive from an ESG perspective.
• The law requirements contribute to the information overload which is already a problem in the current legal framework and is expected to worsen according to the provision of the Retail Investment Strategy.

For the most specific and technical aspects of the Call for Evidence, please, consult the ESBG response.

Full Consultation Response
Author Info

ESBG’s response to the Commission’s consultation on withholding tax procedures

On 13 September 2023, ESBG submitted its response to the consultation launched by the European Commission in June 2023 on the “New EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes”. In its response, ESBG raised several concerns and proposed essential changes to the Commission’s measures.

One of the primary concerns raised by ESBG pertains to the flexibility given to Member States in choosing withholding tax procedures. The Commission’s proposal allows Member States some options, which ESBG argues may further de-harmonize the internal market.
ESBG also expressed reservations about the impact of extensive new obligations on credit institutions. Such measures will have a considerable impact on the internal processes of credit institutions and will require extensive technical adjustments, especially in the already extremely complex securities settlement systems.

ESBG emphasised the need to define terms such as “beneficial ownership” and the “record date” to make these definitions homogeneous.
Regarding legal entities, ESBG urged clarification on whether the legal form (partnership vs. corporation) of the source state or the state of residence is relevant to withholding tax procedures. This clarification is crucial to avoid conflicts.

ESBG also stressed the importance of ensuring that banks are not obligated to provide information under certain circumstances, such as when clients do not provide the required data. Imposing such obligations without exceptions could result in significant costs for banks.
Furthermore, ESBG called for regulations that make data easily accessible, especially concerning the chain of custody.

When states commission private third parties like banks to carry out withholding tax refunds, it should be clear whether banks can charge a fee for this service.
One of ESBG’s strongest objections was to Article 11 since it imposes a number of obligations on institutions for which they should be liable under Art. 16. ESBG proposed that it should be rejected altogether.
Additionally, ESBG emphasised the importance of providing sufficient time for implementation. Last but not least, ESBG stressed that eTRC should be available without an additional charge.

Executive SummaryFull Position Paper

Marta Kajda – Legal Advisor
e.: marta.kajda@wsbi-esbg.org
t.:+32 2 211 11 69

WSBI-ESBG Extend Solidarity and Call for Continued Support in the Aftermath of Morocco Earthquake

WSBI-ESBG Extend Solidarity and Call for Continued Support in the Aftermath of Morocco Earthquake

Brussels, 11 September 2023 – The World Savings and Retail Banking Institute (WSBI) and the European Savings and Retail Banking Group (ESBG) jointly express their deepest condolences and unwavering support to the people of Morocco, especially our Moroccan members, Al Barid Bank and Caisse de Dépôt et de Gestion, in the wake of the devastating earthquake that struck the region.

The recent earthquake has brought immense challenges to the people of Morocco, causing significant damage to infrastructure and resulting in the loss of precious lives. Our thoughts are with all those affected by this tragedy, and we extend our heartfelt sympathies to the families and communities grappling with its aftermath.

WSBI and ESBG recognize the immediate international financial assistance that has been provided to Morocco to aid in relief and recovery efforts. The rapid response of the international community to offer support during this difficult time has been commendable. However, the scale of destruction and the needs of the affected population are extensive, and more assistance is urgently required.

The heads of the World Bank, International Monetary Fund, African Union and the European Commission, together with the presidents of France and India, pledged in a joint statement to “mobilise their technical and financial tools and assistance” to help Morocco. Also, The International Federation for Red Cross and Red Crescent Societies (IFRC) has released over $1 million from its emergency disaster fund to support the Moroccan Red Crescent’s work on the ground. We hereby call upon governments, international organizations, financial institutions, and individuals worldwide to come together and contribute generously to the relief and rebuilding efforts in Morocco.

Moroccan Red Crescent Society rescue teams are on the ground with the International Federation of Red Cross and Red Crescent Societies to support search and rescue operations and provide medical and transportation. You can donate to their Disaster Response Emergency Fund here. UNICEF said it is ready to help the Moroccan government with immediate needs. UNICEF is accepting donations. Doctors Without Borders, which responds to medical emergencies around the world, said it is sending teams to Morocco to assess local needs and provide support if necessary. It is collecting donations here.

Al Barid Bank, our esteemed member, has played a crucial role in providing banking services and financial support to the Moroccan people. In this challenging time, we applaud their dedication and resilience in serving their customers and communities, and we pledge our full support to assist them in their efforts to aid the earthquake-affected areas.

WSBI and ESBG reaffirm their commitment to promoting financial inclusion, sustainability, and community development. We will continue to work closely with our members and partners to explore avenues for additional assistance and support to help Morocco recover and rebuild stronger.

In this time of adversity, we stand united with Morocco and its people. Together, we can make a difference and provide hope for a brighter future for all those affected by the earthquake.

Press contact:
Nihan Cevirgen

Communications Manager
Tel. +32 2211 1190 l GSM. +32 (0) 490 57 43 29

About WSBI

Founded in 1924, WSBI brings together savings and retail banks from 64 countries, representing savings and retail banks worldwide. WSBI focuses on international regulatory issues that affect the savings and retail banking industry and provides a platform for knowledge exchange between member banks. Its aim is to achieve sustainable, inclusive, and balanced growth and job creation. Supporting a diversified range of financial services to meet customer needs, WSBI favors an inclusive form of globalization that is just and fair. It supports international efforts to advance financial access and financial usage for everyone. WSBI recognizes that there are always lessons to be learned from savings and retail banks from different environments and economic circumstances. It, therefore, fosters the exchange of experience and best practices among its members and supports their advancement as sound, well-governed, and inclusive financial institutions.

About ESBG:
The European Savings and Retail Banking Group (ESBG) has 21 members in 17 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 6,300 billion, serve 163 million Europeans and employ nearly 610,000 people. ESBG is the regional arm of the WSBI. Both organisations are headquartered in Brussels. Website: https://www.wsbi-esbg.org/

ESBG responds to Commission’s call for feedback on its legislative package on CMDI

On 31 August, ESBG shared its feedback with the European Commission on the legislative package which aims to review the Crisis Management and Deposit Insurance (CMDI) framework, including four legislative texts (SRMR, BRRD, DGSD and the Daisy Chain proposal). While ESBG members recognize the need to enhance and to strengthen the current framework, they oppose the review overall for the following reasons:

-Resolution scope: The EU Commission proposed to extend the resolution scope through a revision of the Public Interest Assessment (PIA) to ensure that resolution tools can also be applied to small and medium sized banks. However, ESBG thinks that this proposal will increases the administrative burden for those institutions, which were classified as “liquidation entities” up until now. In addition, the associated increase in capital requirements (MREL) could also have a negative impact on lending opportunities on a local scale. That is why ESBG rejects the reference to “regional level” within the definition of critical functions, as well as the reversal of the principle after that.

-Funding in resolution: ESBG disagrees with the EU Commission’s proposal to strengthen funding in resolution by complementing the internal loss-absorbing capacity of institutions, with the use of DGS funds in order to facilitate the access to the Single Resolution Fund (SRF). ESBG members fear that the potentially wider used industry-funded safety nets (DGS and resolution funds) and the extension of the deposit protection (public entities, client funds held by non-bank financial institutions) would cause disproportionate additional contributions which could threaten the profitability of the European banks compared to their international peers.

-Liquidity in resolution: Considering that the current safety nets might not be able to provide sufficient liquidity in resolution if several banks or a G-SIB faced liquidity crisis, they could usefully be complemented with a liquidity-in-resolution tool. Such a tool, would contribute to ensure an effective and credible overall EU crisis management framework, avoiding unwarranted or increasing ex-ante contributions to existing resources.

-DSG alternative and preventive measures: Although they are maintained in the amended framework, the new requirements are very time-consuming, especially for the preventive measures which are neither credibly, functional nor feasible in the future. ESBG cannot understand why proven preventive measures should be restricted in the future.

-General depositor preference: Regarding the Commission’s proposal to amend the hierarchy of claims with the introduction a single tiered ranking of all deposits, ESBG emphasizes that unsecured creditors in resolution/liquidation may bear losses before corporate deposits, compared to today when both bear losses at the same time.

Executive SummaryFull Position Paper

Christophe Hennebelle
Advisor- Recovery, Resolution And Deposit Insurance Policy
t.:+32 2 211 11 62