General comments
• The members of the EACB welcome the opportunity to comment on the Commission interim report on Sustainable Finance.
• As local and regional banks, co-operatives play a key role in financing the energy transition, by promoting within their networks the distribution of investment or savings products in favour of sustainable development; through their expertise in project financing in accompanying energy transition; through their green financing geared to SMEs and energy efficiency financing of private and public buildings. Some co-operative banks are leaders in green bonds.
• Beyond that, co-operative banks are engaged in a long term relationships with members, clients and the communities they belong to. They reinvest significant portions of their available profits back into the community by financing social and cultural projects.
• However the current complexity and continuous motion of the regulatory framework is heavily impacting the local co-operative banks. Additionally, there is a risk that regulation will lead to a less diverse banking environment that would undermine the sustainability and stability of the financial framework in Europe 1. Those are key issues to address in the debate on sustainable finance.
• This is why from a co-operative, retail and local focused institutions' point of view, we think that it is important to highlight the fact that "sustainable" finance is already being carried out in Europe through banks' balance sheets, mostly putting deposits at work for the benefit of the real economy.
• In this light we suggest that at European and international level a greater emphasis is put on the retail side of green financing by promoting tools and policy measures that are conducive of regional green growth via SMEs, households and local actors.
• As the EU Commission’s HLEG is mainly composed of experts in asset management and insurance sector but no retail bankers, a priority shall be to correct this deficit by integrating the local financing dimension in the final recommendations. Co-operative banks shall be closely involved.