EBA欧洲银行-CP33_UniCredit-Group_3页_209kb

UniCredit Group's Reply to CEBS CP 33 on Implementation Guidelines regarding Instruments referred to in Article 57(a) of Directive 2006/48/EC Recast

Core Content

UniCredit Group (UCG) has provided feedback on the CEBS CP 33, which outlines implementation guidelines for capital instruments under Article 57(a) of Directive 2006/48/EC recast. The response reflects UCG's support for harmonisation and the creation of a level playing field, especially in light of the challenges posed by the recent financial crisis. The group's experts have thoroughly reviewed the proposed criteria and expressed general comfort with the CEBS proposal.

Main Points

UCG has addressed several key questions regarding the clarity and justification of the guidelines:

1. Clarity of Guidelines on Instrument Features

• 1.1. UCG believes the guidelines related to the features of capital instruments are sufficiently clear and does not require further elaboration.
• 1.2. They do not identify any circumstances where indirect issuances would be justified, indicating a preference for direct issuance processes.

2. Clarity of Guidelines on Permanence

• 2.1. The guidelines on permanence are deemed clear by UCG.
• 2.2. The group does not see any situations where prior approval for redemptions and buy-backs would not be justified, suggesting that such approvals are necessary in all cases.

3. Clarity of Guidelines on Flexibility of Payments

• 3.1. UCG considers the guidelines regarding the flexibility of payments to be sufficiently clear.
• 3.2. They do not identify any scenarios where the restrictions on payments, including non-fixed amounts and caps, would not be justified. This implies that payment restrictions are essential for maintaining capital adequacy and regulatory compliance.

4. Clarity of Guidelines on Loss Absorbency

• 4.1. The guidelines on loss absorbency are found to be clear by UCG.
• 4.2. The group does not see any additional issues that CEBS should consider regarding loss absorbency features, whether in going concerns or in liquidation.

Key Information

• UCG supports the harmonisation of regulations and the promotion of a level playing field.
• The group's experts have reviewed the CEBS proposal and found it to be sufficiently clear in all areas.
• There are no identified justifications for indirect issuances, or for exceptions to payment restrictions or prior approvals for redemptions and buy-backs.
• No further issues regarding loss absorbency are highlighted.

Contact Information

Area Heads

• Philipp Waldstein Wartenberg – Strategic Funding
  Email: Philipp.Waldstein@unicreditgroup.eu

• Maurizio Cravero – Capital Management
  Email: Maurizio.cravero@unicreditgroup.eu

• Sergio Lugaresi – Regulatory Affairs
  Email: Sergio.Lugaresi@unicreditgroup.eu

CEBS Contact

• Marco Laganà – Regulatory Affairs
  Email: Marco.Laganà@unicreditgroup.eu

Experts

• Andrea Laruccia – Head of Debt Capital Markets, Strategic Funding
  Email: Andrea.Laruccia@unicreditgroup.eu

• Roberta Antinarella – Capital Management
  Email: Roberta.Antinarella@unicreditgroup.eu