The European Association of co-operative Banks (EACB) welcomes the opportunity to comment on the Commission’s proposal for a securitisation Regulation and a proposal to amend the CRR regarding the capital treatment of securitisations.
The members of the European Association of co-operative Banks (EACB) share the view that a functioning securitisation market – supplementing bank loans as a main financing instrument – is essential to support growth, and for providing sufficient credit to companies, particularly to small and medium-sized enterprises (SMEs).
Securitisation is indeed a very important element, also from our perspective as cooperative banks, as it fills a "middle ground" between direct bank lending and pure capital markets funding. That is, allowing smaller banks (for instance within cooperative networks) to finance their lending to SMEs and individuals through an access to the capital markets that makes it possible to generate high-rated securities backed by such kind of retail lending. It also allows to better diversify risks and unlock capital in order to improve local lenders' ability to continue financing and boosting economic growth in their regions.
In this context the members of EACB welcomes the Commission’s proposal to create a securitization framework as an important step in the context of the Capital Markets Union project (CMU). However, we consider that a few further improvements would be desirable in order to enhance the effectiveness of this initiative and to support particularly smaller regional and/or decentralised banking groups in their core activities.
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