EU/European issues

Euro Alliance of Payment Schemes (EAPS)
Financial Services Action Plan (FSAP)
Retail markets
Consumer policy strategy
Consumer Credit Directive
Attachment of bank accounts
EU framework for investment funds
Integration of European mortgagemarkets
Institutional development of European financial services supervision
Obstacles to cross-border mergers and acquisitions in the EU financial services industry
Clearing and settlement
SEPA - Single Euro Payments Area
New Legal Framework for Payments in the Internal Market
Revision of capital requirements for banks and investment firms
Markets in Financial Instruments Directive (MiFID)
Contractual obligations (Rome I)
Corporate gavernance/company law


Euro Alliance of Payment Schemes (EAPS)

The Euro Alliance of Payment Schemes is a joint initiative by a group of European payment schemes to enable European cardholders and retailers to make card payments and cash withdrawals with payment cards across Europe's national boundaries. At present partners from Great Britain, Italy, Spain, Portugal, Netherlands, Germany and a European ATM network are committed to the initiative.

The objective of the Euro Alliance of Payment Schemes is to offer participating banks an alternative to co-branding with international card schemes.

European card payments will start to be processed under the Alliance rules well before the SEPA deadline of January 2008.
www.card-alliance.eu

Financial Services Action Plan (FSAP) and further integration of the financial services markets

Now that the legislative work on the European Union's Financial Services Action Plan (FSAP) is complete, the focus of debate has shifted to future measures to integrate Europe's financial markets. The Association of German Banks is actively involved in this discussion of financial services policy for the period to 2010.

There can be no question, as things stand, of there being a true single market for financial services. Further action is needed to create an internal market for retail customers, optimise European supervisory structures and eliminate obstacles to mergers and acquisitions in the financial sector. The Association of German Banks sets out arguments for continuing the integration of European financial services markets in its booklet of the same name.
Booklet

The Association of German Banks commented individually and in collaboration with other organisations on the European Commission's December 2005 White Paper on Financial Services Policy 2005-2010.
Comments of the Association of German Banks [PDF - 42 KB]
Comments of the Zentraler Kreditausschuss [PDF - 72 KB]
Comments of the European Banking Federation [PDF - 128 KB]
Comments of the European Banking Industry Committee [PDF - 83 KB]

At the end of 2005 the European Commission also called on interested parties to describe their experience to date with the FSAP legislative and consultation process. This consultation does not address the economic impact of FSAP measures, which is to be evaluated in 2008 and 2009. The Association of German Banks commented in the Zentraler Kreditausschuss (ZKA).
Comments of the Zentraler Kreditausschuss [PDF - 64 KB]
Comments of the European Banking Federation [PDF - 234 KB]
Comments of the European Banking Industry Committee [PDF - 219 KB]

To prepare for an evaluation of the economic impact of the Financial Services Action Plan (FSAP), the European Commission conducted a workshop on methodology on 25 October 2006 in Brussels. The Association of German Banks took part in the workshop and submitted the following written comments:
Comments [PDF - 62 KB]

Association of German Banks comments on the European Commission Green Paper of 3 May 2005 “Financial Services Policy 2005-2010”:
Comments [PDF - 224 KB]

Retail markets

Integrating Europe's retail financial services markets is a key objective for the future. In early May 2007 the European Commission set out its strategy in a Green Paper on Retail Financial Services in the Single Market. The Association of German Banks commented as follows:
Comments [PDF - 861 KB]

Consumer policy strategy

The Commission is revising the EU consumer acquis. The Association of German Banks submitted joint comments to the European Commission's Green Paper through the Zentraler Kreditausschuss and also commented separately on selected issues.
ZKA comments [PDF - 771 KB]
Comments of the Association of German Banks [PDF - 202 KB]

Consumer Credit Directive

Comments of the Zentraler Kreditausschuss (ZKA) and the German Insurance Association (GDV) on the European Commission's revised proposal for a directive on credit agreements for consumers:
ZKA comments [PDF - 325 KB]

The Commission intends to revise the Consumer Credit Directive of 1986 and introduce new information requirements and liability rules for financial institutions. The Association of German Banks commented on the revised draft directive in the Zentraler Kreditausschuss (ZKA).
ZKA comments [PDF - 213 KB]



Attachment of bank accounts

The European Commission published a green paper entitled “Improving the Efficiency of the Enforcement of Judgements in the European Union: the Attachment of Bank Accounts”. The Association of German Banks commented on the paper in the Zentraler Kreditausschuss (ZKA): The European Commission published a green paper entitled “Improving the Efficiency of the Enforcement of Judgements in the European Union: the Attachment of Bank Accounts”. The Association of German Banks commented on the paper in the Zentraler Kreditausschuss (ZKA):
ZKA comments [PDF - 53 KB]



EU framework for investment funds

The end of 2006 saw the European Commission publish a White Paper on the Enhancement of the EU Framework for Investment Funds. In its preceding green paper the Commission had called for evidence and comments on a number of proposals aimed at establishing a more efficient internal market for investment funds. The Commission takes the view that the existing UCITS directives, while representing an important first step towards an integrated and competitive European market for investment funds, still leave the full potential of the industry unrealised.
ZKA comments [PDF - 59 KB]



Integration of European mortgage markets

On 19 July 2005 the European Commission issued a Green Paper on Mortgage Credit in the EU inviting the financial services industry, associations and consumer protection organisations to comment on the integration of Europe’s mortgage markets. The joint response by the Zentraler Kreditausschuss (ZKA), the German Insurance Association (GDV) and the German Association of Building Societies also addresses the recommendations previously published by the Forum Group on Mortgage Credit and calls for an approach to market integration based on competition.
Comments [PDF - 87 KB]

Institutional development of European financial services supervision

In June 2006 the Association of German Banks published a position statement on institutional aspects of financial supervision in Europe. The work carried out by CEBS and CESR is welcomed, especially measures aimed at moving forward the convergence of supervisory practices in member states. But the transparency of the committees' work still has room for improvement, as does the involvement of market participants in this work. In the medium term, the consolidated supervisor concept should be expanded to form a system under which lead supervisors would have final responsibility for supervising banking groups in the EU. Financial market integration could culminate in a European system of supervisory authorities, within which large financial institutions involved in cross-border business on a significant scale would be directly supervised by a European Financial Services Agency.
Position paper [PDF - 93 KB]

Against the backdrop of a series of publications by the Commission, the European Parliament and CESR on the integration of European financial services markets, the development of supervisory structures is a key item on the political agenda in Brussels. In January 2005 the Association of German Banks issued a position paper examining the way forward to a system of European financial services authorities with a supranational supervisory authority to regulate cross-border companies.
Position paper [PDF - 1393 KB]

Obstacles to cross-border mergers and acquisitions in the EU financial services industry

At the informal Ecofin of the EU's finance ministers in September 2004, the CEOs of ABN Amro, BNP Paribas and the Royal Bank of Scotland drew attention to the obstacles to cross-border mergers and acquisitions in the financial services industry. The European Commission responded by launching an intensive round of consultation with industry and associations. The Association of German Banks contributed to the debate with the following position paper.
Position paper [PDF - 103 KB]



Clearing and settlement

For further information please click here.



SEPA - Single Euro Payments Area

For further information please click here
Website of the European Payments Council (EPC)

The Association of German Banks has published a booklet in the series “Figures | Facts | Arguments”.
Booklet


New Legal Framework for Payments in the Internal Market

For further information please click here



Revision of capital requirements for banks and investment firms

Comments of the Zentraler Kreditausschuss (ZKA) of 23 June 2006 on technical aspects of the management of interest rate risk in the banking book and concentration risk under the supervisory review process:
ZKA comments Stellungnahme ZKA - englisch [PDF - 368 KB]
For further information please click here.



Markets in Financial Instruments Directive (MiFID)

For further information please click here.



Contractual obligations (Rome I)

In December 2005 the European Commission published a proposal for a Regulation on the law applicable to contractual obligations (Rome I). The Association of German Banks commented on the proposal together with other German and European associations.
Joint comments [PDF 82 KB]



Corporate governance/company law
Comments of the Association of German Banks on the European Commission's Communication on a simplified business environment in the areas of company law accounting and auditing:
Comments [PDF - 125 KB]