Mellékletek:

• monthly-report-on-regulatory-issues-eact-1-september-2014-for-publicatio-.pdf

Mellékletek:

• monthly-report-on-regulatory-issues-eact-27-june-2014-for-publication.pdf

Mellékletek:

• monthly-report-on-regulatory-issues-eact-28-may-2014-for-publication.pdf

Mellékletek:

• monthly-report-on-regulatory-issues-eact-19-march-2014-for-publication.pdf

The EACT has commented on the latest EU proposals for regulation of credit rating agencies and the report of ECON in Parliament on these. The EACT believes that some of the measures proposed by the Commission would have material negative consequences on the use of ratings by corporate issuers, the real economy participants in the rating process. We emphasise once again how the financial regulatory agenda needs to take proper account of how end users in the real economy are impacted.

The EACT's Chairman, Richard Raeburn, was invited to give evidence to the ECON committee of the European Parliament on 6 February 2011, on the subject of the Financial Transaction Tax (FTT). The proposal raises a number of issues that are political in nature, on which the EACT will of course not engage. Richard's speech focuses on the extent to which the FTT, if implemented, will give rise to significant cost increases within the financial system; he questions whether this cost will be absorbed by financial institutions, suggesting that the likelihood is that the 'real economy' - companies, individuals and pension funds - will in practice be asked to carry the additional cost. Such an outcome is both bad for employment and growth; it may also reduce the strength of financial regulation within Europe, as companies seek to move their transactions to areas where the FTT or its equivalent is not being charged.

The European Association of Corporate Treasurers (EACT) has sent an open letter to the Commissioners of the European Union, expressing grave concern over how, in its development of financial regulatory proposals, Brussels takes account of their impact on employment, growth and stability in the real economy.

The letter has been signed by 188 European companies and its release follows that of a similar letter in January 2010. The EACT’s new letter to the Commissioners urges them to ensure that in the development of financial regulatory proposals there is a proper dialogue with the end-users of financial services and products. Whilst the EACT strongly supports the actions being taken to strengthen the oversight of the financial system, its experience is that inadequate attention is paid to a proper understanding of the inter-connectedness between financial regulation and the real economy.

Of immediate concern to the EACT is that proposals currently being made in Brussels for Directives and regulations over capital requirements in the banking sector (CRD IV and CRR) and financial instruments’ markets (MiFID and MiFIR) threaten to reverse the economic value of the exemption granted to end-users of derivatives in the final version of the proposals (EMIR) now being confirmed by the European Union.

EACT Chairman Richard Raeburn was invited to give evidence on the EU's proposals for bank capital requirements (CRD IV), at a meeting of the ECON committee of the European Parliament on 11 October 2011. In his speech he argues that it is vital that the new capital requirements regime does not cut across the value of the exemption won for corporate use of derivatives in the proposed EMIR regulation. He also focuses on the impact of CRD IV on borrowing costs, overall access to funding, trade finance and the EU's international competitiveness.

The EACT has for some time been pushing for the European Commission and the ECB to reassess the quality of governance of the SEPA process.  The issue was raised as an agenda item at the most recent SEPA Council meeting, where the EACT Chairman Richard Raeburn represents both the EACT and Business Europe.  Following that meeting the EACT was invited, along with the national stakeholder organisations handling the implementation of SEPA, to comment in response to two questions about SEPA governance.

The EACT continues to argue strongly that there needs to be a clear distinction between the work of the European Payments Council in practical implementation of SEPA products and processes, on the one hand, and strategic oversight of SEPA on the other hand.  In the case of the latter our view is that end-users, as vital stakeholders in SEPA, have not had a proper voice and the SEPA initiative has paid inadequate attention to end-users.

In our response to the Commission's questions we state clearly that the SEPA Council should have an enhanced role, in which it is seen by the Commission and the ECB as providing strategic input on SEPA to the two institutions.  We argue that for this role to be effective it should be expected that resources are made available to the SEPA Council as necessary; these would allow the Council to take a properly informed view of the issues in its meetings.  The overall intention is that all stakeholders, rather than simply the banking industry, should be able to take a lead in making a success of SEPA.

The EACT has submitted a comment letter in response to the IASB's consultation on hedge accounting; this is part of the overall work being done to replace IAS 39 and therefore a major project of great concern to corporate treasurers. Our comment is broadly supportive of the IASB's proposals but we emphasise changes that should be met in order to reinforce the practical relevance of the new standard as to how treasurers actually manage risk.
Mellékletek:

• eact_letter_in_response_to_iasb_ed_2010_13.pdf

The EACT has responded to the latest consultation by the European Commission on Markets in Financial Instruments Directive (MiFID). This work will eventually lead to a new Directive which will incorporate important issues that affect the way treasurers operate both as users of financial instruments and as investors.
Mellékletek:

• mifid_consultation_2010_answer_eact.pdf

The European Commission launched a consultation in November 2010 on credit ratings agencies. We have responded to the consultation and the full document can be read here. The EACT welcomes the Commission's initiative in publishing a working document for discussion and consultation purposes. Credit ratings play a key role in the financial system for issuers as well as investors, contributing to financial stability and supporting the prospects for growth. The provision of ratings underpins the pricing of debt and adds to market liquidity, both of which are key elements in open and competitive markets.

There is understandable concern, following the financial crisis of 2008, that change is needed. However, the EACT hopes that, as the Commission moves forward to develop proposals, it will take due account of what works well at present and avoid endorsing proposals that may be politically attractive but lack substance in analysis and fact.

Mellékletek:

• eact_response_to_cra_consultation_jan2011.pdf

Európai Treasury Szövetség támogatásunkat és állásfoglalásunkat kéri az alábbi két dokumentummal kapcsolatban. 

Észrevételeiteket illetve hozzájárulásotokat küldjétek az onodyt@wallis.hu címre november 30-ig.

Mellékletek:

• derivatives_key_messages.doc
• derivatives_general_paper.doc