Positions
Latest position papers published by WSBI and ESBG. Responses to consultations and letters submitted to the European Commission and other policymaking bodies appear in many of the published papers.
Digital euro: ESBG’s response to the European Commission targeted consultation
The European Savings and Retail Banking Group stated the need to further assess exactly what gaps in the payments system could be filled by the introduction of a digital euro, and to analyse how the existing solutions could be adjusted to enhance their value to the customer. This in its response to the European Commission targeted consultation.
ESBG supports consumer participation in capital markets
The EU Retail Investment Strategy aims to increase the level of retail investor participation in the EU’s capital markets and ensure that retail investors can take full advantage of capital markets, achieve better outcomes and better cater for their long-term financial needs. The upcoming MiFID II Review (under the umbrella of the EU Retail Investment Strategy) provides an opportunity to contribute to this goal. The European Savings and Retail Banking Group puts forward its calls in support for an inclusive EU capital market.
ESBG calls for more feasible rules on the new corporate sustainability due diligence
In its response to the European Commission call for feedback on the proposal for a Directive on Corporate Sustainability Due Diligence, the European Savings and Retail Banking Group (ESBG) suggests changes to make the rules more feasible. ESBG members support the goal to tackle environmental issues and human rights abuses as they commit to sustainable, responsible and future-oriented banking and support the creation of a coherent legal framework. Nevertheless, ESBG finds that the proposal foresees a role for financial entities that is too ambitious and could create legal uncertainty.
ESBG submits its position to the International Accounting Standards Board on IFRS 17
ESBG believes that this does not correctly portray the insurance service provided under these contracts. We are of the opinion that an alternative approach based on the present value of expected future annuity payments would more accurately determine the quantity of insurance contract services provided by their contracts.
ESBG welcomes horizontal cybersecurity requirements for digital products
ESBG’s response to the European Commission consultation on the Cyber Resilience Act, a regulation on horizontal cybersecurity requirements for digital products. The European Savings and Retail Banking Group welcomes the initiative but believes it could be improved. The ESBG’s position focuses on the following aspects: Cybersecurity of digital products and the users of digital products; Improving the cybersecurity of digital products; and Stakeholder impact of potential regulatory measures.
An open data economy should be multilateral and cross-sectoral
ESBG’s response to the European Commission consultation on the proposed Data Act calls for a horizontal regulatory approach to establish a consistent and harmonised rules for all sectors. ESBG is the European Savings and Retail Banking Group.
ESBG response to ESMA’s consultation on guidelines of MiFID II suitability requirements
ESBG’s response to the European Securities and Market Authority (ESMA) consultation on some MiFID II sustainability aspects. European banks calls for clear procedures and to avoid unnecessary administrative burdens.
Developing a proportionate, fair and efficient IRRBB framework in the EU
On 4 April 2022, ESBG responded to the EBA consultation specifying technical aspects of the revised framework capturing interest rate risks for banking book (IRRBB) positions.
European Commission review of the Mortgage Credit Directive
SBG sent its response to the European Commission questionnaire on what to include in the upcoming Review of the Mortgage Credit Directive (MCD).
Digital euro: ESBG’s response to the European Commission targeted consultation
The European Savings and Retail Banking Group stated the need to further assess exactly what gaps in the payments system could be filled by the introduction of a digital euro, and to analyse how the existing solutions could be adjusted to enhance their value to the customer. This in its response to the European Commission targeted consultation.
ESBG supports consumer participation in capital markets
The EU Retail Investment Strategy aims to increase the level of retail investor participation in the EU’s capital markets and ensure that retail investors can take full advantage of capital markets, achieve better outcomes and better cater for their long-term financial needs. The upcoming MiFID II Review (under the umbrella of the EU Retail Investment Strategy) provides an opportunity to contribute to this goal. The European Savings and Retail Banking Group puts forward its calls in support for an inclusive EU capital market.
ESBG calls for more feasible rules on the new corporate sustainability due diligence
In its response to the European Commission call for feedback on the proposal for a Directive on Corporate Sustainability Due Diligence, the European Savings and Retail Banking Group (ESBG) suggests changes to make the rules more feasible. ESBG members support the goal to tackle environmental issues and human rights abuses as they commit to sustainable, responsible and future-oriented banking and support the creation of a coherent legal framework. Nevertheless, ESBG finds that the proposal foresees a role for financial entities that is too ambitious and could create legal uncertainty.
ESBG submits its position to the International Accounting Standards Board on IFRS 17
ESBG believes that this does not correctly portray the insurance service provided under these contracts. We are of the opinion that an alternative approach based on the present value of expected future annuity payments would more accurately determine the quantity of insurance contract services provided by their contracts.
ESBG welcomes horizontal cybersecurity requirements for digital products
ESBG’s response to the European Commission consultation on the Cyber Resilience Act, a regulation on horizontal cybersecurity requirements for digital products. The European Savings and Retail Banking Group welcomes the initiative but believes it could be improved. The ESBG’s position focuses on the following aspects: Cybersecurity of digital products and the users of digital products; Improving the cybersecurity of digital products; and Stakeholder impact of potential regulatory measures.
An open data economy should be multilateral and cross-sectoral
ESBG’s response to the European Commission consultation on the proposed Data Act calls for a horizontal regulatory approach to establish a consistent and harmonised rules for all sectors. ESBG is the European Savings and Retail Banking Group.
ESBG response to ESMA’s consultation on guidelines of MiFID II suitability requirements
ESBG’s response to the European Securities and Market Authority (ESMA) consultation on some MiFID II sustainability aspects. European banks calls for clear procedures and to avoid unnecessary administrative burdens.
Developing a proportionate, fair and efficient IRRBB framework in the EU
On 4 April 2022, ESBG responded to the EBA consultation specifying technical aspects of the revised framework capturing interest rate risks for banking book (IRRBB) positions.
European Commission review of the Mortgage Credit Directive
SBG sent its response to the European Commission questionnaire on what to include in the upcoming Review of the Mortgage Credit Directive (MCD).
