31 August 2012

EBIC: Key positions in first half of 2012

In the first half of 2012, under the Chairmanship of Mr Joseph Delhaye, the European Banking Industry Committee (EBIC) has been focusing on strategic areas of prudential supervision, retail banking and anti-money laundering.

To this end it published a number of key position papers, including:

• 12 February: ‘EBIC observations on the Commission Recommendation on access to a basic payment account and the IMCO Working Document’, in which EBIC welcomed the Commission’s soft-law approach to the issue of access to a basic payment account as this allowed taking into account different national situations currently in place;
• 5 April: ‘EBIC preliminary observations on the Consumer Market Study on consumers’ experiences with bank account switching’, where EBIC expressed its reservations concerning the methodology and final conclusions of the Consumer Market Study and further it confirmed its commitment to promoting bank account mobility achieved through the implementation of EBIC Common Switching Principles;
• 6 June: ‘EBIC letter on the current review of the Regulation on Credit Rating Agencies’, in which EBIC welcomed the objectives of the European Commission to further enhance the regulation of CRAs, but at the same time expressing its concerns about the mandatory rotation of these agencies;
• 12 June: ‘EBIC response to the European Commission consultation on Bank Accounts’, supporting the general objectives of ensuring clear, easily accessible and comparable information on fees for consumers, customer mobility and financial inclusion, and recommending full-fledged assessment of the existing EU and national measures which have been put in place in the course of recent years before any further action at EU level is considered;
• 15 June: ‘EBIC response to the European Commission report on the application of the 3rd Anti-Money Laundering Directive’,  highlighting the need for guidance on a number of AML issues, while adhering to the Risk-Based-Approach, as well as raising awareness of increasing compliance costs linked to this vital public function fulfilled by European banks;
• 11 July: ‘EBIC Position paper on CARRP ahead of trialogue negotiations’, addressing a number of outstanding concerns in relation to the Commission Proposal for a Directive on Credit Agreements Relating to Residential Property ahead of the trialogue negotiations.
• 3 August: EBIC letter concerning the implementation of the Capital Requirements Regulation and the Capital Requirements Directive IV, supporting the European institutions in the challenging negotiations concerning the CRR/CRD IV, and stressing the need for a reasonable period of time between the final agreement on CRR and CRD IV and the implementation of the new rules, in order to allow banks to put in place the necessary procedures to comply with the new rules;
• Also in the first half of 2012 EBIC expressed its views concerning the Consumer Credit Directive on several occasions. EBIC supports the initiative taken by the European Parliament to address its views on the transposition of the CCD and its forthcoming review, and believes that the review process should be conducted in a transparent way and involve all relevant stakeholders.

Press release

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