ESBG s Position Paper on the Commission Consultation on Bank Accounts ESBG (European Savings Banks Group)

Size: px
Start display at page:

Download "ESBG s Position Paper on the Commission Consultation on Bank Accounts ESBG (European Savings Banks Group)"

Transcription

1 ESBG s Position Paper on the Commission Consultation on Bank Accounts ESBG (European Savings Banks Group) Rue Marie-Thérèse, 11 - B-1000 Brussels ESBG Register ID June 2012

2 Doc 0675/2012 RDE/LGU/MIS ANSWERS TO QUESTIONS Question 1: Do you consider that the information provided by banks on bank account fees is presented to consumers in a sufficiently clear manner and easy to compare between banks? What good practices could you identify? What are the persisting shortcomings? Do you think that amendments to the transparency obligations in the Payment Services Directive (2007/64/EC) could address those shortcomings? The EU legislation currently in force, coupled with national and self-regulatory measures provides a solid ground for the transparency and comparability of bank fees. ESBG believes that the current provisions of the Payment Services Directive (PSD), the national legislative and self-regulatory measures taken by public authorities and non-profit organisations, are sufficient. No further EU legislative measure is necessary. Should further measure be proven to be necessary, proportionate and cost-effective, sufficient flexibility should be left at national level. ESBG strongly encourages the Commission to carry out an objective and balanced assessment of all evidence at hand, as well as a cost-benefit analysis, before any policy decisions be made concerning transparency and comparability of bank account fees. According to ESBG s impression, and based on evidence, the Commission failed to be well-balanced in its analysis. ESBG members are committed to continuously improve the transparency and comparability to follow nationally the evolving needs of consumers. The developed draft Principles on transparency and comparability of personal current account fees have indeed been based on identified good practices and would have effectively assisted European consumers in accessing, understanding and comparing information on bank account fees. Question 2: Do you think that standardising bank account fee terminology could help to provide more transparent and comparable information on fees? If terminology were to be standardised, should that standardisation cover all fees or only some of them? If only some of them, on the basis of which criteria should they be chosen? Should terminology be standardised at national or EU level? 2

3 The use of common terminology should be performed at national rather than European level, based on the specificities of the national markets, and can add value only if restricted to the most common services. The savings banks industry is willing to work on defining a common terminology at national level. This common terminology would refer to services, not fees and should not mean a standardisation of products in any case. It should also be limited to the most common services identified. Indeed, even with the use of common terminology of the most common terms, banks should be free to portray their identity towards the consumer by using brand names, especially for marketing and advertising materials. Maintaining the ability to use brand names is also beneficial for consumers, who may be more familiar with the brand names. Banks must be allowed to differentiate their offer from other banks as long as it is clear to the consumer what service is concerned. This is crucial for competitiveness and a diversified market which is in the customer interest. Question 3: Do you think that glossaries of terms and standardised lists of bank fees would facilitate comparability? If so, what format and content should this information have? What body/forum would you consider appropriate to develop such a glossary/standardised list of fees? For the glossaries to be useful for the end-user, and to allow comparison, they have to be concise. Thus, ESBG considers that any glossaries should cover a well-identified number of most typical services used by customers. Therefore, the related vocabulary must be developed nationally, possibly in cooperation with other stakeholders. We further stress that their use should not impose any form of product standardisation as continued freedom to develop and offer innovative and economic products to customers is essential. Finally, credit institutions should not be obliged to provide glossaries to their customers. It should suffice, when additional information is made easily available that consumers are informed how to access the information. This will help to avoid unnecessary costs for credit institutions. Question 4: In order to further increase bank account fee transparency and comparability, which of the following tools should be considered: i) comparison websites managed by public authorities ii) standardised cost simulations to be provided by banks iii) standardised representative examples to be provided by banks iv) surveys by consumer organisations/financial ombudsman v) any other tools you consider relevant? Should any of them be made compulsory? What would be the likely costs? 3

4 European savings and retail banks are focusing on providing a quality service and are not orientated on a pure price-based competition. There are many elements of service that may be important to the consumer and influence their preferences, such as a close branch network, advisory quality, distribution structures, online banking services, innovative technology, quality of the service, to name only a few. If the price is seen as the only distinctive mark, consumers might get a false impression, that all bank accounts are more or less the same. This might be misleading for consumers as they might choose a model that does not fit their personal needs. Furthermore a pure price-based comparison has adverse effects on credit institutions that - as savings banks - offer their customers many additional services. Therefore, the focus on the price might distort competition. Comparison websites, whose independence should be guaranteed, should encompass other parameters and should not be limited to fees only, so that they are correctly informing customers. ESBG also believes that comparison websites might be run by public authorities or independent bodies. What is important is that appropriate mechanisms are ensured to monitor the quality of the comparison service provided. Timeliness is also critically important. Regarding standardised cost simulations, ESBG reminds the Commission that standardised cost simulations imply high costs as there is no such thing as an average/typical/standard consumer. There are as many customer behavioral patterns as there are customers themselves. Therefore in order to have a workable standardised cost simulation the amount of input and statistical information will be huge and costly to implement. It should also be born in mind that examples could be representative for some consumers, but not for others (for those, they might even be confusing). Therefore the usefulness of standardised cost simulations is relative. Question 5: What level of detail should the information on actual fees paid have and how frequently should it be provided to the account holder? Would having comparable information on the fees actually paid encourage consumer mobility, including on a cross-border basis? ESBG considers that the current provisions of the PSD, with the options for Member States on periodic disclosure, coupled with national legislative and self-regulatory measures and actions taken by public authorities and non-profit organisations, provide a solid ground for the transparency and comparability of bank fees (see answer to question 1). Following the entry into force of the PSD, all savings and retail banks already fulfil the requirement to provide ex-ante and ex-post information. The PSD introduced an obligation on all payment services providers to provide the user (i.e. the consumer) with information on the charges for the payment transactions before and after the execution of the payment, including the information on actual fees paid and the frequency of the information provided. On these grounds there is no reason to impose any further obligations on credit institutions. Lastly, ESBG considers that cross-border consumer mobility is more affected by language barriers, cultural differences, and fiscal barriers of Member States. The level of detail of the ex-post information on fees should simply depend on the structure of fees paid by the consumer. Last but not least, it appears very important for consumers that a branch of the account-keeping credit institution is near their place of residence. From our point of view, it seems to be precluded 4

5 that any measures on transparency of costs might encourage customer mobility on a cross-border basis. Question 6: What other measures/instruments should be considered in order to improve the transparency and comparability of bank fees? Please describe and indicate at which level (national or EU) you consider they should be taken. The current EU legislation provides a solid ground for the transparency and comparability of bank fees at national level. Since the measures are relatively new, ESBG does not consider that, at this stage, further EU legislative proposals would be appropriate, by amending the PSD or otherwise. Should any further measure be deemed necessary, a sufficient flexibility should be left at national level. ESBG welcomed the fact that the national approach addressing retail banking issues was taken by Commission representatives during the 2010 European Consumer Summit, as well as in the Commission s letter of 20 October 2010, in which the Commission explained its expectations from the ESBG self-regulation, where it is stated that the solutions should be developed and implemented at national level. ESBG strongly recommends maintaining this line of thinking because during the work which followed this invitation it became even more apparent that finding a common denominator at EU level would not be possible it is challenging enough at national level. On this occasion, we would like to stress that consumers and non-profit organisations also have an important role to play in parallel to the efforts made by the banking industry and actions taken by legislators and enforcers. The 2012 study on bank fees finds that they [consumer organisations] appear well informed about the personal current account markets, consumer behaviour. Thus, while banks fully appreciate their responsibilities, the role of consumer organisations and public authorities should not be neglected. Finally, ESBG would like to stress the need for financial education. This element is also part of the grand scheme of improving transparency and comparability for consumers. Question 7: Do banks in the Member State where you have a bank account offer a switching service? If yes, is it in line with the Common Principles on bank account switching described above? Is information on the conditions of switching presented in a consumer friendly manner? In January 2008, the Commission invited EBIC to develop principles for banks conduct if a consumer wishes to switch his personal current account. These Common Principles were formally adopted by EBIC, acknowledged by the Commission and have therefore effectively been implemented from 1 November Question 8: If a switching service in line with the Common Principles is offered by banks in the Member State where you have a bank account, does it remove all obstacles to bank account switching? If not, what obstacles remain? Provide examples of good practices and persisting obstacles encountered. Yes, it does remove all obstacles. Some further time might be needed to let the service demonstrate its effectiveness. 5

6 Making the switching procedure easier does not necessarily translate into higher customer mobility. Banks and customers build a long term relationship which often results in a low mobility rate due to the consumer s trust and satisfaction 1 ESBG also noted shortcomings in the methodology used in conducting the mystery shopping exercise, published by the European Commission, which says that 8 out of 10 mystery shoppers faced difficulties when switching bank accounts. Among these, there were a very low number of respondents from large countries. Some questions were asked which go further than the Common Principles and contradictions between the results of the Consumer Market Study and those of other studies, including a recent Eurobarometer study (February 2012). It is worthwhile acknowledging that the latter study covers a much larger sample of the European population and therefore is expected to provide more reliable conclusions. Its main findings are as follows: Among European current account holders, 85% have not switched or tried to switch as they do not need to, while 7% say they switched and it was easy and [only] 3% say they have not switched or tried to switch as it is too difficult or too much hassle. Just 1% switched and found it difficult, with another 1% saying they tried to switch but gave up. Question 9: Should the Common Principles remain voluntary? What do you consider are the advantages or disadvantages of making them compulsory at EU level? What would be the likely costs? EBIC Common Principles should remain voluntary. ESBG believes that the Common Principles allow enough flexibility so that individual Member States can continue using their different systems switching services, legal and technical constraints. In view of these differences, ESBG believes that it would be difficult to have compulsory switching principles at EU level. While the efficiency of the process could still be improved, this will be driven by a better awareness and better communication between the interested stakeholders and not by imposed legislation as such. Question 10: Should switching principles/measures also cover cross-border switching of bank accounts? The Common Principles should not be extended to cover cross-border switching of bank accounts. It is felt that because of the nature of account switching, it should only apply at national level. This is particularly so in the absence of any data suggesting that there is latent need for such approach. Implementing a set of common principles for cross-border switching in the future would, in any case, require significant cost-benefit evidence in order to be justified.. Question 11: According to you, how important is the risk of having receipts, bills and payments misdirected when switching bank accounts? What measures could be considered to make the switching process safer? 1 See for example: Commission Staff Working Document, SEC (2007) 106, 31 January 2007: it is likely that a large proportion of banking customers probably the majority in most Member States would describe themselves as satisfied with their current bank. ; additionally see Expert Group on Customer Mobility in Relation to Bank Accounts where studies concerning customer satisfaction are illustrated, allocating a customer satisfaction up to 94%. 6

7 ESBG is convinced that the EBIC Common Principles help to facilitate effective switching. Any problems that may occur due to receipts, bills and payments misdirected when switching bank accounts, may be due to the variety of participants. We therefore believe that better awareness and better communication between the parties (banks, customers and providers) could improve both the efficiency of the process and the perception of customers about switching. Question 12: What obstacles, if any, are still faced by account providers that are smaller or established in another Member State to expand their client base or to enter new markets? Are these connected to problems with switching facilities? These obstacles are much wider than considerations related to bank account switching. Obstacles include: 1.) high costs to build a brand, trust and a branch network; 2.) the necessity of translating documentation for consumers of different nationalities. Question 13: What other measures should be considered to improve bank account switching? Please describe. EBIC s Common Principles were first implemented in November They were the first common standards on bank account switching providing a benchmark for all Member States. As the Consumer Market Study on consumers experiences with bank account switching rightly points out, the Common Principles outline the right approach to simplify the switching process. Notably, where the Common Principles are used, consumers consider the process to be running smoothly. 2 In some areas progress is still ongoing and further work is being carried out. Therefore, ESGB considers that no further measures are necessary or have to be considered to improve bank account switching. Question 14: Do you dispose of information on consumers encountering difficulties in access to a basic bank account? What types of obstacles are signalled by the consumers preventing them from having access to a basic bank account? ESBG believes that financial exclusion forms part of a much wider social exclusion problem. However, it is appropriate to differentiate between consumers unable to obtain access to a bank account, and those who do not wish to have one. Against this background, voluntary social exclusion cannot be easily removed through legislation. However, national authorities, in cooperation with the relevant stakeholders, including ESBG members, are best placed, in respect to the principle of subsidiarity, to take adequate measures adapted to their local specific situations. Question 15: Are you aware of any measures taken by banks or other institutions in the Member State where you have your residence to facilitate access to a basic payment account? Have these initiatives been successfully enforced? 2 GfK Final Report Consumer Market Study on the consumers experiences with bank account switching with reference to the Common Principles on Bank Account Switching, p

8 It is important to acknowledge that the initiatives adopted by the industry meet the needs of different European markets by taking into account the different rates of market penetration and levels of financial inclusion of the population. Question 16: Do these measures also facilitate access to a basic payment account for nonresidents? In general, it is important to make a distinction between the social (access to BPA) and internal market (cross-border access for EU residents) policy approaches. In our view if the very purpose is to combat financial exclusion, a basic bank account should be granted only to unbanked European residents consumers. In addition ESBG believes that with the purpose of combating financial exclusion, a basic bank account should be granted with adequate compliance to Anti-Money Laundering legislation, and with at least an objective economic link with the country in which they want to open an account. Question 17: If consumers still have difficulties in opening a bank account, what are the reasons for that? Please refer to the answers provided to Questions 14 and 16. Question 18: If more needs to be done what additional measures should be envisaged? Should the problem be tackled at national or EU level? ESBG believes that in the wider context of the fight against social exclusion, all actors in society (public authorities, industry, NGOs, consumers, civil society, Trade Unions) should work together towards achieving common solutions to fulfil this responsibility. 8

9 About ESBG (European Savings Banks Group) ESBG The European Voice of Savings and Retail Banking ESBG (European Savings Banks Group) is an international banking association that represents one of the largest European retail banking networks, comprising of approximately one-third of the retail banking market in Europe, with total assets of over 7,470 billion, non-bank deposits of 3,400 billion and non-bank loans of 4,000 billion (31 December 2010). It represents the interests of its members vis-à-vis the EU Institutions and generates, facilitates and manages high quality crossborder banking projects. ESBG members are typically savings and retail banks or associations thereof. They are often organised in decentralised networks and offer their services throughout their region. ESBG member banks have reinvested responsibly in their region for many decades and are a distinct benchmark for corporate social responsibility activities throughout Europe and the world. ESBG - Association internationale sans but lucratif/internationale vereniging zonder instoogmerk/ International not-for-profit association Rue Marie-Thérèse, 11 B-1000 Brussels Tel: Fax: Published by the ESBG, January

European Banking Federation response to the European Commission consultation on bank accounts

European Banking Federation response to the European Commission consultation on bank accounts D0910C-2012 12.06.2012 European Banking Federation response to the European Commission consultation on bank accounts Launched in 1960, the European Banking Federation is the voice of the European banking

More information

European Commission Consultation on Bank Accounts

European Commission Consultation on Bank Accounts European Commission Consultation on Bank Accounts The Law Society of Scotland s Response EU Interest Representative Register ID: 80169287043-57 May 2012 1 INTRODUCTION The Law Society of Scotland aims

More information

Response to a consultation

Response to a consultation Response to a consultation 12/06/2012 Consultation on bank accounts Question 1: Do you consider that the information provided by banks on bank account fees is presented to consumers in a sufficiently clear

More information

FBF position paper on the European Commission's proposal for a Directive on bank accounts ****

FBF position paper on the European Commission's proposal for a Directive on bank accounts **** Paris, June 2013 FBF position paper on the European Commission's proposal for a Directive on bank accounts The French Banking Federation (FBF) is the professional body that represents all banks operating

More information

ESBG amendment proposals Regulation on interchange fees for card-based payment transactions

ESBG amendment proposals Regulation on interchange fees for card-based payment transactions ESBG amendment proposals Regulation on interchange fees for card-based payment transactions November 2013 Doc 1059/2013/Vers 1.0 NBI ESBG amendment proposals Regulation on interchange fees for card-based

More information

Response of the French Banking Federation (FBF) to the Consultation of the European Commission on Bank Accounts

Response of the French Banking Federation (FBF) to the Consultation of the European Commission on Bank Accounts Paris, June 12, 2012 Response of the French Banking Federation (FBF) to the Consultation of the European Commission on Bank Accounts The Fédération Bancaire Française (the French Banking Federation, hereinafter

More information

Eurofinas reply to the Joint Committee of the European Supervisory Authorities (ESAs) Consultation Paper on guidelines for cross-selling practices

Eurofinas reply to the Joint Committee of the European Supervisory Authorities (ESAs) Consultation Paper on guidelines for cross-selling practices Eurofinas reply to the Joint Committee of the European Supervisory Authorities (ESAs) Consultation Paper on guidelines for cross-selling practices 20 March 2015 Eurofinas is entered into the European Transparency

More information

Instant retail payments for Europe: a Blueprint

Instant retail payments for Europe: a Blueprint Instant retail payments for Europe: a Blueprint February 2015 Instant retail payments for Europe: a Blueprint It is indispensable to debate instant payments now. In an ever more interconnected, always-on

More information

Public Consultation Paper: Payment Accounts Directive. Department of Finance. July 2015

Public Consultation Paper: Payment Accounts Directive. Department of Finance. July 2015 DIRECTIVE ON PAYMENT ACCOUNTS Public Consultation July 2015 Public Consultation Paper: Payment Accounts Directive Department of Finance July 2015 Department of Finance Government Buildings, Upper Merrion

More information

COMMON PRINCIPLES FOR BANK ACCOUNTS SWITCHING

COMMON PRINCIPLES FOR BANK ACCOUNTS SWITCHING European Banking Federation (EBF) European Savings Banks Group (ESBG) European Association of Cooperative Banks (EACB) European Mortgage Federation (EMF) European Federation of Building Societies (EFBS)

More information

Delegations will find attached the draft Council conclusions on a Capital Markets Union, as prepared by the Economic and Financial Committee.

Delegations will find attached the draft Council conclusions on a Capital Markets Union, as prepared by the Economic and Financial Committee. Council of the European Union Brussels, 16 June 2015 (OR. en) 9852/15 EF 110 ECOFIN 473 SURE 14 UEM 223 NOTE From: To: Subject: General Secretariat of the Council Permanenet Representatives Committee (Part

More information

FINANCIAL INCLUSION: ENSURING ACCESS TO A BASIC BANK ACCOUNT

FINANCIAL INCLUSION: ENSURING ACCESS TO A BASIC BANK ACCOUNT FINANCIAL INCLUSION: ENSURING ACCESS TO A BASIC BANK ACCOUNT CONSULTATION DOCUMENT - COMMON RESPONSE Question 1: Do you share the Commission's overall objective to ensure that, by a certain date, every

More information

Insurance Europe response to the Commission Staff Working Document on Consumer Protection in third-pillar retirement products.

Insurance Europe response to the Commission Staff Working Document on Consumer Protection in third-pillar retirement products. Position Paper Insurance Europe response to the Commission Staff Working Document on Consumer Protection in third-pillar retirement products. Our reference: LIF-PEN-13-052 Date: 19 July 2013 Referring

More information

Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. on electronic invoicing in public procurement. (Text with EEA relevance)

Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. on electronic invoicing in public procurement. (Text with EEA relevance) EUROPEAN COMMISSION Brussels, 26.6.2013 COM(2013) 449 final 2013/0213 (COD) Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on electronic invoicing in public procurement (Text with

More information

ETNO Reflection Document in reply to the EC consultation on Future networks and the Internet early challenges regarding the Internet of things

ETNO Reflection Document in reply to the EC consultation on Future networks and the Internet early challenges regarding the Internet of things ETNO Reflection Document in reply to the EC consultation on Future networks and the Internet early challenges regarding the Internet of things November 2008 Executive Summary The Internet of the future

More information

European Youth Forum Policy Paper Guiding Principles on Common Objectives for Voluntary activities and Greater understanding of young people

European Youth Forum Policy Paper Guiding Principles on Common Objectives for Voluntary activities and Greater understanding of young people European Youth Forum Policy Paper Guiding Principles on Common Objectives for Voluntary activities and Greater understanding of young people Adopted by the Council of Members, 21-22 November 2003 Rome

More information

Basic banking services

Basic banking services Presentation to the European Parliament by London Economics 25 January 2012 1 Presentation outline Basic facts and benefits 2 and benefits Background Access to basic banking is essential in modern society,

More information

DEUTSCHE BANK RESPONSE TO THE REPORT OF THE EXPERT GROUP ON CUSTOMER MOBILITY IN RELATION TO BANK ACCOUNTS

DEUTSCHE BANK RESPONSE TO THE REPORT OF THE EXPERT GROUP ON CUSTOMER MOBILITY IN RELATION TO BANK ACCOUNTS Deutsche Bank Dr. Bernhard Speyer/Dr. Stefan Schäfer Deutsche Bank AG/DB Research P.O. Box 60272 Frankfurt, Germany e-mail: stefan-a.schaefer@db.com Tel. +49 (0)69 910 31832 Fax +49 (0)69 910 31743 03.09.2007

More information

ROADMAP. Initial IA screening & planning of further work

ROADMAP. Initial IA screening & planning of further work ROADMAP Title of the initiative: Youth programme post 2013 Type of initiative (CWP/Catalogue/Comitology): CWP Lead DG: DG EAC/E-2, Youth in Action Unit Expected date of adoption of the initiative (month/year):

More information

Mr Roger Marshall Acting President EFRAG Board European Financial Reporting Advisory Group (EFRAG) 35 Square de Meeüs 1000 Brussels Belgium

Mr Roger Marshall Acting President EFRAG Board European Financial Reporting Advisory Group (EFRAG) 35 Square de Meeüs 1000 Brussels Belgium * esma European Securities and Markel:s Authority *** The Chair 19 November2015 ESMA/2015/1739 Mr Roger Marshall Acting President EFRAG Board European Financial Reporting Advisory Group (EFRAG) 35 Square

More information

Personal current accounts in the UK

Personal current accounts in the UK Personal current accounts in the UK An OFT market study Executive summary July 2008 EXECUTIVE SUMMARY Background The personal current account (PCA) is a cornerstone of Britain s retail financial system.

More information

HDE position on legislative package to regulate payment systems (MIF and PSD II)

HDE position on legislative package to regulate payment systems (MIF and PSD II) [Transparency Register No.: 31200871765-41] HDE position on legislative package to regulate payment systems (MIF and PSD II) November 2013 I. Einleitung I. Introduction The German Retail Federation HDE

More information

1. CURRENT TRENDS 2. THE ROLE OF E-COMMERCE IN PROMOTING ACCESS TO FINANCIAL SERVICES 3. OBSTACLES TO E-COMMERCE FOR CREDIT PROVIDERS

1. CURRENT TRENDS 2. THE ROLE OF E-COMMERCE IN PROMOTING ACCESS TO FINANCIAL SERVICES 3. OBSTACLES TO E-COMMERCE FOR CREDIT PROVIDERS Consultation response on the future of Electronic Commerce in the Internal Market and the implementation of the Directive on Electronic Commerce (2000/31/EC) October 2010 EXECUTIVE SUMMARY 1. CURRENT TRENDS

More information

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE EN EN EN EUROPEAN COMMISSION Brussels, COM(2010) COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Removing cross-border tax obstacles

More information

General remarks. Page 1 of 6

General remarks. Page 1 of 6 Frankfurt am Main, 14. April 2010 Sophie Ahlswede Deutsche Bank AG/DB Research P.O. Box 60262 Frankfurt, Germany e-mail: sophie.ahlswede@db.com Tel. +49 (0)69 910 31832 Deutsche Bank response to the public

More information

BEREC Guidelines for Quality of Service in the scope of Net Neutrality

BEREC Guidelines for Quality of Service in the scope of Net Neutrality BEREC Guidelines for Quality of Service in the scope of Net Neutrality BEUC response to the public consultation Contact: Guillermo Beltrà digital@beuc.eu Ref.: X/2012/060-27/07/2012 BUREAU EUROPÉEN DES

More information

Key Points. Ref.:EBF_004742 Brussels, 04 November 2013

Key Points. Ref.:EBF_004742 Brussels, 04 November 2013 Ref.:EBF_004742 Brussels, 04 November 2013 European Banking Federation Position Paper on the European Commission Proposal for a Regulation on Interchange Fees for Card-Based Payment Transactions Launched

More information

1. Introduction. 1 http://www.centralbank.ie/regulation/poldocs/consultationpapers/documents/cp75/consultation%20paper%20cp75%20final.

1. Introduction. 1 http://www.centralbank.ie/regulation/poldocs/consultationpapers/documents/cp75/consultation%20paper%20cp75%20final. National Consumer Agency submission to the Central Bank of Ireland s consultation paper: Additional Consumer Protection Requirements for Debt Management Firms 1. Introduction 1.1. The National Consumer

More information

ROADMAP. A. Context and problem definition

ROADMAP. A. Context and problem definition TITLE OF THE INITIATIVE ROADMAP Commission Communication on EU Risk management and supply chain security LEAD DG RESPONSIBLE UNIT TAXUD B2 DATE OF ROADMAP 10 / 2012 This indicative roadmap is provided

More information

CALL FOR EVIDENCE EU REGULATORY FRAMEWORK FOR FINANCIAL SERVICES

CALL FOR EVIDENCE EU REGULATORY FRAMEWORK FOR FINANCIAL SERVICES EUROPEAN COMMISSION Directorate-General for Financial Stability, Financial Services and Capital Markets Union INVESTMENT AND COMPANY REPORTING Economic analysis and evaluation CALL FOR EVIDENCE EU REGULATORY

More information

Insurance Europe response to Joint Committee consultation on guidelines for cross-selling practices

Insurance Europe response to Joint Committee consultation on guidelines for cross-selling practices Insurance Europe response to Joint Committee consultation on guidelines for cross-selling practices Our reference: COB-DIS-15-038 Date: 20 March 2015 Contact person: Arthur Hilliard, Policy Advisor, Conduct

More information

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 2013/0139 (COD) DIRECTIVE OF THE EUROPEAN PARLIAMT AND OF THE COUNCIL of on the comparability of fees related to payment accounts, payment account switching and access to payment accounts with basic features

More information

Visa Europe Our response to the European Commission s proposed regulation of interchange fees for card-based payment transactions

Visa Europe Our response to the European Commission s proposed regulation of interchange fees for card-based payment transactions Visa Europe Our response to the European Commission s proposed regulation of interchange fees for card-based payment transactions Executive summary On 24 July 2013 the European Commission published a proposal

More information

Registration must be carried out by a top executive or a number of executives having the power to commit the whole company in the EU.

Registration must be carried out by a top executive or a number of executives having the power to commit the whole company in the EU. Questions and answers 1- What is the purpose of The Initiative? Why are we doing this? The purpose of the Supply Chain Initiative is to promote fair business practices in the food supply chain as a basis

More information

CCBE POSITION ON THE PROPOSED ELECTRONIC IDENTITY AND

CCBE POSITION ON THE PROPOSED ELECTRONIC IDENTITY AND CCBE POSITION ON THE PROPOSED ELECTRONIC IDENTITY AND TRUST SERVICES REGULATION (COM(2012) 238/2) CCBE Position on the proposed electronic identity and trust services regulation (COM(2012) 238/2) The Council

More information

EACB messages for the Trialogue negotiations on Bank Recovery and Resolution Directive

EACB messages for the Trialogue negotiations on Bank Recovery and Resolution Directive EACB messages for the Trialogue negotiations on Bank Recovery and Resolution Directive 30 August 2013 The EACB is the voice of the co-operative banks in Europe. It represents, promotes and defends the

More information

The Commission proposal is in the left column, our suggestions in the right column. Recital 46. deleted

The Commission proposal is in the left column, our suggestions in the right column. Recital 46. deleted EDRi amendments on the proposed Regulation laying down measures concerning the European single market for electronic communications and to achieve a Connected Continent, and amending Directives 2002/20/EC,

More information

FINANCIAL INSTITUTIONS Retail issues, consumer policy and payment systems

FINANCIAL INSTITUTIONS Retail issues, consumer policy and payment systems EUROPEAN COMMISSION Internal Market and Services DG FINANCIAL INSTITUTIONS Retail issues, consumer policy and payment systems Brussels, 6.2.2009 MARKT/H3/MI D(2009) FINANCIAL INCLUSION: ENSURING ACCESS

More information

COMMISSION STAFF WORKING DOCUMENT SUMMARY OF THE IMPACT ASSESSMENT. Accompanying the document

COMMISSION STAFF WORKING DOCUMENT SUMMARY OF THE IMPACT ASSESSMENT. Accompanying the document EUROPEAN COMMISSION Brussels, 7.3.2012 SWD(2012) 23 final COMMISSION STAFF WORKING DOCUMENT SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a Regulation of the European Parliament

More information

CONSULTATION DOCUMENT CMU ACTION ON CROSS-BORDER DISTRIBUTION OF FUNDS (UCITS, AIF, ELTIF, EUVECA AND EUSEF) ACROSS THE EU

CONSULTATION DOCUMENT CMU ACTION ON CROSS-BORDER DISTRIBUTION OF FUNDS (UCITS, AIF, ELTIF, EUVECA AND EUSEF) ACROSS THE EU EUROPEAN COMMISSION Directorate-General for Financial Stability, Financial Services and Capital Markets Union FINANCIAL MARKETS Asset management CONSULTATION DOCUMENT CMU ACTION ON CROSS-BORDER DISTRIBUTION

More information

Jarmila Tkacikova, Ph.D. Bank Accounts over Europe: tradition & tools & trends

Jarmila Tkacikova, Ph.D. Bank Accounts over Europe: tradition & tools & trends Jarmila Tkacikova, Ph.D. Bank Accounts over Europe: tradition & tools & trends Cycle of 10 European Workshops Mutual Learning on Financial Inclusion Opening European Workshop with Certificate 2008 OPENING

More information

The European Qualifications Framework for Lifelong Learning (EQF)

The European Qualifications Framework for Lifelong Learning (EQF) European Qualifications Framework The European Qualifications Framework for Lifelong Learning (EQF) Europe Direct is a service to help you find answers to your questions about the European Union Freephone

More information

EBA FINAL draft Regulatory Technical Standards

EBA FINAL draft Regulatory Technical Standards EBA/RTS/2015/03 03 July 2015 EBA FINAL draft Regulatory Technical Standards on resolution colleges under Article 88(7) of Directive 2014/59/EU Contents 1. Executive summary 3 2. Background and rationale

More information

Insurance Europe Position Paper on the proposal for the fourth AML Directive. Our reference: LIF-AML-13-032 Date: 14 May 2013

Insurance Europe Position Paper on the proposal for the fourth AML Directive. Our reference: LIF-AML-13-032 Date: 14 May 2013 Position Paper Insurance Europe Position Paper on the proposal for the fourth AML Directive Our reference: LIF-AML-13-032 Date: 14 May 2013 Referring to: COM(2013) 45 final - 2013/0025 (COD) Related documents:

More information

Eurofinas is entered into the European Transparency Register of Interest Representatives with ID n 83211441580-56

Eurofinas is entered into the European Transparency Register of Interest Representatives with ID n 83211441580-56 Eurofinas response to the European Commission s Green Paper Towards an integrated European market for card, internet and mobile payments (COM(2011) 941 final) April 2012 Eurofinas is entered into the European

More information

EPIF POSITION PAPER ON PAYMENT INITIATION SERVICES (PIS)

EPIF POSITION PAPER ON PAYMENT INITIATION SERVICES (PIS) JULY 2013 EPIF POSITION PAPER ON PAYMENT INITIATION SERVICES (PIS) EPIF, founded in 2011, represents the interests of the non-bank payment institutions ( PI ) sector at the European level. We currently

More information

COMMISSION OF THE EUROPEAN COMMUNITIES REPORT FROM THE COMMISSION TO THE COUNCIL

COMMISSION OF THE EUROPEAN COMMUNITIES REPORT FROM THE COMMISSION TO THE COUNCIL EN EN EN COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 15.9.2008 COM(2008) 552 final REPORT FROM THE COMMISSION TO THE COUNCIL in accordance with Article 18 of Council Directive 2003/48/EC on taxation

More information

Australian Charities and Not-for-profits Commission: Regulatory Approach Statement

Australian Charities and Not-for-profits Commission: Regulatory Approach Statement Australian Charities and Not-for-profits Commission: Regulatory Approach Statement This statement sets out the regulatory approach of the Australian Charities and Not-for-profits Commission (ACNC). It

More information

BBA response to consultation on access to basic bank accounts

BBA response to consultation on access to basic bank accounts Ms Maris Ilves European Commission Internal Market and Services DG B-1049 Brussels Belgium BBA register ID number: 5897733662-75 6 April 2009 Dear Ms Ilves, BBA response to consultation on access to basic

More information

PUBLIC CONSULTATION ON POSTAL SERVICES

PUBLIC CONSULTATION ON POSTAL SERVICES EUROPEAN COMMISSION PUBLIC CONSULTATION ON POSTAL SERVICES PART 2 CONSULTATION ENDS JAN 27 2006 NOV 2005 V1.9 Page 1 of 9 PART 2 CONSULTATION ON POSTAL SERVICES Part 2 asks more detailed questions on a

More information

It is both an honour and a pleasure for me to be here and to celebrate with

It is both an honour and a pleasure for me to be here and to celebrate with Drivers for change in payment and securities settlement systems Gertrude Tumpel-Gugerell European Central Bank Introduction It is both an honour and a pleasure for me to be here and to celebrate with you

More information

Message 791 Communication from the Commission - SG(2012) D/50777 Directive 98/34/EC Notification: 2011/0188/D

Message 791 Communication from the Commission - SG(2012) D/50777 Directive 98/34/EC Notification: 2011/0188/D Message 791 Communication from the Commission - SG(2012) D/50777 Directive 98/34/EC Notification: 2011/0188/D Reaction of the Commission to the response of a Member State notifying a draft regarding a

More information

Decision on the CMA s review of the Credit Cards (Merchant Acquisition) Order 1990

Decision on the CMA s review of the Credit Cards (Merchant Acquisition) Order 1990 Decision on the CMA s review of the Credit Cards (Merchant Acquisition) Order 1990 Contents Page Summary... 1 Introduction... 2 Background... 4 Monitoring activity... 7 Market developments... 7 Stakeholder

More information

8485/15 SC/GDLC/io 1 DGB 1

8485/15 SC/GDLC/io 1 DGB 1 Council of the European Union Brussels, 5 May 2015 (OR. en) 8485/15 NOTE From: To: Special Committee on Agriculture Council No. prev. doc.: 7524/2/15 REV 2 Subject: AGRI 242 AGRIORG 26 AGRILEG 100 AGRIFIN

More information

VAT Treatment of Cross Border Transactions in the Single Market

VAT Treatment of Cross Border Transactions in the Single Market RESPONSE TO GREEN PAPER COM (2010) 695 On the Future of VAT Introduction The European Council of Optometry and Optics (ECOO) would like to thank you for this opportunity to submit views. As an organisation

More information

GENERAL POSITION FOR THE PARLIAMENT OF THE CZECH REPUBLIC - WHITE PAPER ON THE INTEGRATION OF EU MORTGAGE CREDIT MARKETS

GENERAL POSITION FOR THE PARLIAMENT OF THE CZECH REPUBLIC - WHITE PAPER ON THE INTEGRATION OF EU MORTGAGE CREDIT MARKETS GENERAL POSITION FOR THE PARLIAMENT OF THE CZECH REPUBLIC - WHITE PAPER ON THE INTEGRATION OF EU MORTGAGE CREDIT MARKETS Ministry of Finance of the Czech Republic 2008-1 - Table of contents: I. General

More information

Achievements and challenges of the single market. S&D responses to citizens top 10 concerns

Achievements and challenges of the single market. S&D responses to citizens top 10 concerns Achievements and challenges of the single market S&D responses to citizens top 10 concerns The European economic model must be based on three principles: competition which stimulates, co-operation which

More information

EBA final draft Regulatory Technical Standards

EBA final draft Regulatory Technical Standards EBA/RTS/2014/11 18 July 2014 EBA final draft Regulatory Technical Standards on the content of recovery plans under Article 5(10) of Directive 2014/59/EU establishing a framework for the recovery and resolution

More information

Eurofinas is entered into the European Transparency Register of Interest Representatives with ID n

Eurofinas is entered into the European Transparency Register of Interest Representatives with ID n Eurofinas observations on the Commission s Proposal for a Regulation of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on

More information

The European Green Paper on Urban Mobility

The European Green Paper on Urban Mobility The European Green Paper on Urban Mobility Dominic Stead OTB Research Institute for Housing, Mobility and Urban Studies Delft University of Technology PO Box 5030 2600 GA Delft The Netherlands tel: +31

More information

Proposal for a Regulation of the European Parliament and of the Council on interchange fees for card-based payment transactions

Proposal for a Regulation of the European Parliament and of the Council on interchange fees for card-based payment transactions Proposal for a Regulation of the European Parliament and of the Council on interchange fees for card-based payment transactions About MasterCard MasterCard is a payments technology company that enables

More information

Strong support. Remaining concerns

Strong support. Remaining concerns EORTC opinion on the proposal for an EU Regulation on clinical trials on medicinal products for human use and the 7 th of June ENVI report on this proposal It is clear that the Commission and appointed

More information

EuroCommerce position paper Online e-payments

EuroCommerce position paper Online e-payments EuroCommerce position paper Online e-payments 16 September 2011 EuroCommerce welcomes the opportunity to comment on online payment issues. We carried out a brief members' survey and consulted within the

More information

The Czech National Bank s opinion

The Czech National Bank s opinion The Czech National Bank s opinion on the European Commission consultation document GREEN PAPER Towards an integrated European market for card, internet and mobile payments (of 11 January 2012) This section

More information

E U R O P E A N E C O N O M I C A R E A

E U R O P E A N E C O N O M I C A R E A E U R O P E A N E C O N O M I C A R E A S T A N D I N G C O M M I T T E E O F T H E E F T A S T A T E S 27 September 2012 SUBCOMMITTEE IV ON FLANKING AND HORIZONTAL POLICIES EEA EFTA Comment on the Proposal

More information

Guidelines. on the data collection exercise regarding high earners EBA/GL/2014/07. 16 July 2014

Guidelines. on the data collection exercise regarding high earners EBA/GL/2014/07. 16 July 2014 EBA/GL/2014/07 16 July 2014 Guidelines on the data collection exercise regarding high earners Contents 1. Executive summary 3 2. Background and rationale 4 3. EBA Guidelines on the data collection exercise

More information

Credit reporting: Towards better access to credit and protection for consumers Elina Pyykkö* ECRI Commentary No. 9 (March 2012)

Credit reporting: Towards better access to credit and protection for consumers Elina Pyykkö* ECRI Commentary No. 9 (March 2012) EU Credit reporting: Towards better access to credit and protection for consumers Elina Pyykkö* ECRI Commentary No. 9 (March 2012) Credit reporting addresses the fundamental problem of credit markets:

More information

FEEDBACK STATEMENT Responses to the Discussion Paper Separate Financial Statements 15 April 2015

FEEDBACK STATEMENT Responses to the Discussion Paper Separate Financial Statements 15 April 2015 FEEDBACK STATEMENT Responses to the Discussion Paper Separate Financial Statements 15 April 2015 Introduction In September 2014, the European Financial Reporting Advisory Group (EFRAG), the Spanish Instituto

More information

Statement. on the. Kenya Communications (Broadcasting) Regulations, 2009. February 2010

Statement. on the. Kenya Communications (Broadcasting) Regulations, 2009. February 2010 Statement on the Kenya Communications (Broadcasting) Regulations, 2009 February 2010 ARTICLE 19 Free Word Centre 60 Farringdon Road London EC1R 3GA United Kingdom Tel +44 207 324 2500 Fax +44 207 490 0566

More information

COMMUNICATION TO THE COMMISSION FROM THE PRESIDENT, MS WALLSTRÖM, MR KALLAS, MS HÜBNER AND MS FISCHER BOEL

COMMUNICATION TO THE COMMISSION FROM THE PRESIDENT, MS WALLSTRÖM, MR KALLAS, MS HÜBNER AND MS FISCHER BOEL COMMUNICATION TO THE COMMISSION FROM THE PRESIDENT, MS WALLSTRÖM, MR KALLAS, MS HÜBNER AND MS FISCHER BOEL PROPOSING THE LAUNCH OF A EUROPEAN TRANSPARENCY INITIATIVE Memorandum to the Commission Compliance

More information

Thank you for the opportunity to submit our comments on Financial Inclusion: Ensuring Access to a Basic Bank Account.

Thank you for the opportunity to submit our comments on Financial Inclusion: Ensuring Access to a Basic Bank Account. Financial Inclusion Ensuring Access to a Basic Bank Account European Commission Internal Market and Services DG Consultation 2009 Response of The Trading Standards Institute April 2009 Ron Gainsford Chief

More information

Response to Department for Business, Enterprise and Regulatory Reform consultation: Legislative options to address illicit P2P file-sharing

Response to Department for Business, Enterprise and Regulatory Reform consultation: Legislative options to address illicit P2P file-sharing Response to Department for Business, Enterprise and Regulatory Reform consultation: Legislative options to address illicit P2P file-sharing 30 October 2008 UK Film Council Legislative options to address

More information

Environmental Claims Findings and Conclusions of the OECD Committee on Consumer Policy. March 2011. Environmental Claims

Environmental Claims Findings and Conclusions of the OECD Committee on Consumer Policy. March 2011. Environmental Claims Environmental Claims Findings and Conclusions of the OECD Committee on Consumer Policy March 2011 Environmental Claims FOREWORD The Committee on Consumer Policy launched a project to examine ways to enhance

More information

European Commission Green Paper on card, mobile and e- payments

European Commission Green Paper on card, mobile and e- payments European Commission Green Paper on card, mobile and e- payments A Cicero Consulting Special Report 2 Contents page Cicero Introduction Page 3 Current payments landscape Page 5 Objectives Page 5 Possible

More information

MOTION FOR A RESOLUTION

MOTION FOR A RESOLUTION EUROPEAN PARLIAMT 2009-2014 Plenary sitting 20.10.2011 B7-0000/2011 MOTION FOR A RESOLUTION further to Question for Oral (O-xxxx/xxxx B7-0000/2011), pursuant to Rule 115(5) of the Rules of Procedure on

More information

ROADMAP. A. Context and problem definition

ROADMAP. A. Context and problem definition ROADMAP TITLE OF THE INITIATIVE Recommendation on best practices in the prevention and combatting of betting related match fixing LEAD DG RESPONSIBLE UNIT MARKT DATE OF ROADMAP 12/2012 This indicative

More information

Council of the European Union Brussels, 26 June 2015 (OR. en)

Council of the European Union Brussels, 26 June 2015 (OR. en) Council of the European Union Brussels, 26 June 2015 (OR. en) Interinstitutional File: 2012/0011 (COD) 9985/1/15 REV 1 LIMITE DATAPROTECT 103 JAI 465 MI 402 DIGIT 52 DAPIX 100 FREMP 138 COMIX 281 CODEC

More information

Strategic Priorities for the Cooperation against Cybercrime in the Eastern Partnership Region

Strategic Priorities for the Cooperation against Cybercrime in the Eastern Partnership Region CyberCrime@EAP EU/COE Eastern Partnership Council of Europe Facility: Cooperation against Cybercrime Strategic Priorities for the Cooperation against Cybercrime in the Eastern Partnership Region Adopted

More information

The positioning of Cyprus as a leading international business centre has been

The positioning of Cyprus as a leading international business centre has been European directive helps The incorporation into local law of the EU merger directive has created the possibility of tax-neutral international mergers using, explains Sophie Stylianou of Eurofast Taxand

More information

2011-2014. Deliverable 3 Supervision of sports agents and transfers of players, notably young players. Expert Group "Good Governance

2011-2014. Deliverable 3 Supervision of sports agents and transfers of players, notably young players. Expert Group Good Governance EU Work Plan for Sport 2011-2014 Expert Group "Good Governance Deliverable 3 Supervision of sports agents and transfers of players, notably young players D e c e m b e r 2 0 1 3 2 1. INTRODUCTION The EU

More information

COMMISSION STAFF WORKING DOCUMENT. Executive Summary of the Impact Assessment. Accompanying the document

COMMISSION STAFF WORKING DOCUMENT. Executive Summary of the Impact Assessment. Accompanying the document EUROPEAN COMMISSION Brussels, 11.9.2013 SWD(2013) 332 final COMMISSION STAFF WORKING DOCUMENT Executive Summary of the Impact Assessment Accompanying the document Proposal for a Regulation of the European

More information

Surcharging is harmful to consumers

Surcharging is harmful to consumers Visa Europe response to the consultation of the Competition and Consumer Section of the Department of Jobs, Enterprise and Innovation on the early transposition of Article 19 of the Consumer Rights Directive

More information

Council of the European Union Brussels, 28 July 2015 (OR. en)

Council of the European Union Brussels, 28 July 2015 (OR. en) Conseil UE Council of the European Union Brussels, 28 July 2015 (OR. en) PUBLIC 11243/15 LIMITE DRS 50 CODEC 1084 NOTE From: To: Subject: General Secretariat of the Council Delegations Proposal for a DIRECTIVE

More information

COMMISSION OF THE EUROPEAN COMMUNITIES. Proposal for a COUNCIL RECOMMENDATION

COMMISSION OF THE EUROPEAN COMMUNITIES. Proposal for a COUNCIL RECOMMENDATION COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 18.02.2005 COM(2005) 53 final Proposal for a COUNCIL RECOMMENDATION on priority actions to increase cooperation in the field of archives in Europe (presented

More information

Re: Accessible Transport Strategy Draft Action Plan 2012 2015

Re: Accessible Transport Strategy Draft Action Plan 2012 2015 Mobility Inclusion Unit Strategic Policy and Co-ordination Division Department for Regional Development Room 301, Clarence Court 10-18 Adelaide Street BELFAST BT28GB 5 April 2012 TO WHOM IT MAY CONCERN

More information

Call for tender: Workshop & Role play Design and Facilitation

Call for tender: Workshop & Role play Design and Facilitation Call for tender: Workshop & Role play Design and Facilitation 16/02/2016 Contents 1. Purpose of the tender... 3 2. EPF - General Information... 3 3. Description of the Seminar... 3 1.1. Objectives of the

More information

Register ID number: 3373670692 24

Register ID number: 3373670692 24 EFAMA reply to European Commission consultation paper on Central Securities Depositories (CSDs) and on the Harmonisation of Certain Aspects of Securities Settlement in the European Union Register ID number:

More information

RECOMMENDATIONS by THE COMPANY LAW SLIM WORKING GROUP on THE SIMPLIFICATION OF THE FIRST AND SECOND COMPANY LAW DIRECTIVES

RECOMMENDATIONS by THE COMPANY LAW SLIM WORKING GROUP on THE SIMPLIFICATION OF THE FIRST AND SECOND COMPANY LAW DIRECTIVES RECOMMENDATIONS by THE COMPANY LAW SLIM WORKING GROUP on THE SIMPLIFICATION OF THE FIRST AND SECOND COMPANY LAW DIRECTIVES Conclusions submitted by the Company Law Slim Working Group I. FIRST COUNCIL DIRECTIVE

More information

Joint conclusions of the Spanish Presidency EU Youth Conference youth employment and social inclusion, Jerez, Spain 13-15 April 2010

Joint conclusions of the Spanish Presidency EU Youth Conference youth employment and social inclusion, Jerez, Spain 13-15 April 2010 Joint conclusions of the Spanish Presidency EU Youth Conference youth employment and social inclusion, Jerez, Spain 13-15 April 2010 Youth Employment is the common theme of the three EU Youth Conferences

More information

Guidelines. Guidelines on certain aspects of the MiFID suitability requirements. 21 August 2012 ESMA/2012/387

Guidelines. Guidelines on certain aspects of the MiFID suitability requirements. 21 August 2012 ESMA/2012/387 Guidelines Guidelines on certain aspects of the MiFID suitability requirements 21 August 2012 ESMA/2012/387 Date: 21 August 2012 ESMA/2012/387 Contents I. Scope 3 II. Definitions 3 III. Purpose 4 IV. Compliance

More information

BRINGING EUROPE S CULTURAL HERITAGE ONLINE, p.9. 1 The New Renaissance. REPORT OF THE COMITÉ DES SAGES REFLECTION GROUP ON

BRINGING EUROPE S CULTURAL HERITAGE ONLINE, p.9. 1 The New Renaissance. REPORT OF THE COMITÉ DES SAGES REFLECTION GROUP ON ACE Response to the Green Paper on the online distribution of audiovisual works in the European Union: opportunities and challenges towards a digital single market The Association des Cinémathèques Europénnes

More information

Before turning to detailed remarks on the questions for consultation, we would like to draw EBA s attention to our key issues and concerns.

Before turning to detailed remarks on the questions for consultation, we would like to draw EBA s attention to our key issues and concerns. Frankfurt am Main 16 August 2013 BVI s position on the Draft Regulatory Technical Standards on the determination of the overall exposure to a client or a group of connected clients in respect of transactions

More information

COMMISSION OF THE EUROPEAN COMMUNITIES

COMMISSION OF THE EUROPEAN COMMUNITIES EN EN EN COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 28.11.2008 COM(2008) 798 final COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE

More information

EU Consultation: Access to a Basic Payment Account. ecdn RESPONSE November 2010

EU Consultation: Access to a Basic Payment Account. ecdn RESPONSE November 2010 ID-No: 88151944552-38 The European Consumer Debt Network is a European civil society network built on the experiences and expertise of debt advice organisations, consumer agencies, financial educators,

More information

Policy Paper on Non-Formal Education: A framework for indicating and assuring quality

Policy Paper on Non-Formal Education: A framework for indicating and assuring quality Policy Paper on Non-Formal Education: A framework for indicating and assuring quality Adopted by the Council of Members/ Extraordinary General Assembly 2-3 May 2008 (Castelldefels, Catalonia - Spain) 0.

More information

THE INTERNAL MARKET IS THE KEY DRIVER FOR ECONOMIC GROWTH

THE INTERNAL MARKET IS THE KEY DRIVER FOR ECONOMIC GROWTH THE INTERNAL MARKET IS THE KEY DRIVER FOR ECONOMIC GROWTH Position of the Austrian Federal Economic Chamber on a future Internal Market Strategy for goods and services July 2015 Contact: In Brussels: Kornelia

More information

Privacy and Transparency for Consumer Trust and Consumer Centrality

Privacy and Transparency for Consumer Trust and Consumer Centrality 1 1 2 2 Ecommerce Europe is the association representing around 5000+ companies selling products and/or services online to consumers in Europe. Ecommerce Europe is a major stakeholder in policy issues

More information

Green paper on the management of biowaste in the European Union

Green paper on the management of biowaste in the European Union COUNCIL OF EUROPEAN MUNICIPALITIES AND REGIONS CONSEIL DES COMMUNES ET REGIONS D EUROPE Green paper on the management of biowaste in the European Union COM (2008) 811 final CEMR RESPONSE Brussels, March

More information

POSITION OF THE NOTARIES OF EUROPE ON THE POST-STOCKHOLM PROGRAMME

POSITION OF THE NOTARIES OF EUROPE ON THE POST-STOCKHOLM PROGRAMME POSITION OF THE NOTARIES OF EUROPE ON THE POST-STOCKHOLM PROGRAMME In ever-increasing numbers, European citizens are living, studying, marrying, divorcing and dying in a Member State other than that in

More information