EUF position paper on CRD IV
The EUF has written to key stakeholders in The European Parliament, the European Commission and Business to comment on the potential effect of Basel III and CRD IV on the Factoring and Commercial Finance Industry. The EUF suggests that the regulators should note that some of the new provisions were designed for deposit taking institutions (as Basel III by definition does not cater for institutions that are not authorised to accept deposits). However, these provisions may also be applied by Member States to non deposit taking institutions such as factoring companies. It is vital that specificities of the European banking and financing industry are considered and upheld in the process of transposing the global Basel III framework. Particularities of certain special forms of financing such as factoring need to be taken into consideration in the transposition process, particularly if they are as vital for SMEs as the factoring and receivables financing industry are.