The EACB welcomes the opportunity to comment on the Commission consultation regarding guidance on the treatment of equity exposures in accordance with Article 133(5) of CRR. We appreciate the intent of providing clarity on the treatment of equity exposures incurred under legislative programmes with the aim of supporting the banking sector in continuing to mobilise equity financing in line with the EU’s strategic priorities.
Cooperative banks contribute to the goals of Recital 10 of CRR III by supporting SMEs, financing investments in renewable energy and in the agricultural sector, promoting affordable housing and digitalisation. In the current environment, marked by the need to scale up investment capacity in sectors of strategic importance for the EU’s growth and social cohesion, applying a 250% risk weight to these equity exposures would significantly restrict banks’ ability to contribute to EU priorities. The Guidance should therefore insist on a broader interpretation of Article 133(5) CRR, one that ensures a wider recognition of these investments under various national or European initiatives.
Finally, we proposed the inclusion of a review clause, ensuring flexibility to adapt to new legislative programmes, and should provide for grandfathering of existing arrangements that already benefit from preferential treatment.