Though the centralisation of the supervision of credit rating agencies with ESMA is justifiable, it is not absolutely necessary. At the same time, it is questionable whether or not it is inn line with EU law. Therefore, the maintenance of federal supervisory structures for ESMA and for the supervision rating agencies is a better solution.
The EU passport for mortgage credit intermediaries removes barriers to the cross-border intermediation of mortgage loans. The professional requirements for credit intermediaries should not be too high. A credit refusal obligation in the case of a negative creditworthiness assessment is not necessary and leads to considerable legal uncertainty. Simplified conditions for early repayment can make fixed-interest credits more expensive. EBA’s arbitration powers are not covered by the EBA-Regulation.
The already restricted option of e-money institutions to issue credits does not constitute a systemic risk, since - unlike credit institutions - e-money institutions must not use money received for payment services for the granting of credits. In this respect, the proposed relaxation of requiremens and ongoing obligations compared to those applicable to credit institutions is indeed justified. Thus the Proposal allows for a reduction of payment transactions costs.
The European Parliament on Tuesday backed a deal to cap the fees retailers pay to process debit and credit card transactions. For cross-border debit card transactions, the agreed fee cap under [...] credit card transactions, fees will be capped at 0.3 per cent of transaction value. The member states are allowed to set a lower fee cap for domestic credit card transactions. cep expert Philipp Eckhardt believes the cap on fees is not a wise measure. “Statutory upper limits on interchange fees affect existing and developing card schemes in equal measure,” Eckhardt explained. “They may even obstruct market
The proposed amendments strengthen the stability of the financial system, though at the expense of economic growth. Taking into account risks emanating from remuneration models is consistent. However, the intended shifting of the burden of proof is not convincing. It contravenes the need to avoid a credit crunch by means of risk-adequate securitisations.
The rules on investment policy, maturity and liquidity increase investor confidence. Cash buffers for money market funds with a constant asset value are not suitable for striking the right balance between investor confidence and financial market stability. The only alternative is a general ban on money market funds with a constant redemption value. Banning money market funds from soliciting external credit ratings from rating agencies obstructs the efficient allocation of capital.
Disclosure obligations for AIF managers who revert to the use of leverage to a high degree enable authorities to better monitor possible risks to the stability of financial markets. Upper limits to the level of leverage and minimum own fund requirements are not necessary. Requirements as to the conduct of AIF, which do not employ leverage, or do so to a very small degree and invest in relatively illiquid assets, are dispensable. An international register on the granting of credits by banks to AIF is necessary.
The clearing of speculative OTC derivatives through central counterparties (CCP) can increase the stability of the financial system. As long as there is no evidence of any systemic risks posed by interest and exchange rates derivatives, only credit default swaps (CDS) should be subject to this clearing obligation. It is questionable whether a clearly defined distinction between speculative OTC derivatives and those serving to hedge real corporate risks is possible at all. In view of the many unanswered questions, the Commission should not wait until 2014 to publish its Report on the systemic
with current account surpluses export capital and thus are net lenders. As they do not need any foreign credits, they are not at risk of insolvency (risk category 1). Countries with current account [...] itself with an interest rate on the capital market that the government could not pay, the Euro Group declared on 25 March 2010 that if necessary, bilateral credits would be granted to Greece in order to [...] interests and repayment of foreign credits are paid back in due time. This definition forms the basis of the CEP Default Index. The CEP assumes that net borrowing should not be used for consumer expenditure
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country’s capability to pay back foreign credits, in other words, their creditworthiness. This does not depend only on the state debt but rather on the solvency of the entire economy. Therefore, the CEP [...] do not need any foreign credits, they are not at risk of insolvency (risk category 1). Countries with current account deficits need foreign capital in order to finance such deficits. There- fore [...] permanently depends on new and higher foreign credits. Since its publication, the findings of the CEP Default Index have been confirmed by numerous events. With its Index, the CEP detected Italy’s and
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