ACCIS Member Roundtable

ACCIS Member Roundtable
22 March 2016,
Vienna
Programme
•
14.00-14.15
Welcome by Gerhard Wagner (KSV1870 Information
GmbH)
•
14.15-15.00
Public Affairs update
•
15.00-16.00
ACCIS management re-structuring project - update
(including Q&A)
•
16.00-16.20
European Code of Conduct project – update
•
16.20-16.40
Cross-border Data Exchange project - update
•
16.40-16.55
AGM & Conference 2016 and WCCRC 2016 – update
•
16.55-17.00
AOB
Public Affairs Update
ACCIS Member Roundtable
22 March 2016,
Vienna
Enrico Lodi, Head of the Public Affairs Working Group
Allocation of dossiers
Dossier(s)
People involved
●
Data Protection and FSUG
Fabrizia Giacomini (L),
Serena Holm, Agnieszka Marzec, Stefan
Reyak, Valerijus Ostrovskis, Federica Boledi
●
Access to Finance, CMU, AnaCredit
Luisa Monti (L), David Pernia Ramirez,
Fabrizia Giacomini, Claudia Pollio, Vlaerijus
Ostrovskis
●
PSD2
Serena Holm (L)
●
Digital Single Market
Emma Thomas (L), Claudia Pollio, Federica
Boledi
●
Retail Financial Services Green Paper
Fabrizia Giacomini (L), Emma Thomas,
Claudia Pollio, Valerijus Ostrovskis
●
ICCR
Fabrizia Giacomini, Luisa Monti, Serena Holm
Agenda
• Data Protection
• AnaCredit
• Retail Financial Services Green Paper
• ACCIS response to FSUG paper
• Capital Markets Union
Data Protection
• On 15 December 2015 European Institutions reached a political agreement on
the General Data Protection Regulation
State of play and timeline:
• Agreed text currently under translation in the different official languages of the EU
by the Council
• April 2016 – expected review and adoption of the text in the LIBE Committee of
the European Parliament (EP)
• April/May 2016 – expected adoption of the text in plenary by the EP
• June 2016 – expected publication of the Regulation in the Official Journal of the
EU
• June 2018 – expected entry into force
Data Protection
All stakeholders, including companies European Institutions
and national authorities have two years to comply with the
new Regulation.
Data Protection
Latest ACCIS Activities:
•
2016 Computer, Privacy and Data Protection Conference (January 2016)
•
Meeting with European Data Protection Assistant Supervisor Wojciech
Wiewiórowski (9 February 2016)
•
PAWG specific call on GDPR and ACCIS strategy (11 March 2016)
•
Gathering of information at the national level on local approaches and
interpretations (on-going)
Envisaged next steps:
• preparation of a high level briefing note to the membership
• gathering of information on the situation in the different MS and possible
threats to our industry
Analytical Credit Datasets (AnaCredit)
• 4 December 2015: publication of draft Regulation on the collection of granular credit
and credit risk data (AnaCredit) by ECB
• Stakeholders where invited to submit their comments
• Main features of the project
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credit institutions will report to National Central Banks an extensive list of data
attributes about loans and borrowers
National Central Banks will pass the reported data to AnaCreidit through the
European Central Bank
Feedback Loop
• The exact date of the adoption of the AnaCredit Regulation currently remains unclear,
but it is likely to be adopted in April-May 2016.
Analytical Credit Datasets (AnaCredit)
ACCIS response
•
Based on the feedback collected, ACCIS submitted its position paper raising the following
concerns:
1. Legal basis and process: potentially incorrect legal basis chosen by the ECB for the
draft Regulation, exceeding its competence related to statistical data collection;
2. Unclear objectives and purpose of the draft regulation and disproportionate
requirements imposed by it;
3. The feedback loop, as it is currently designed in the draft Regulation could impact
negatively the competitive position of private credit reporting service providers (CRSP).
4. Lack of data protection safeguards in the draft regulation;
5. The draft regulation could result in excessive reporting burden imposed on credit
institution. In order to avoid imposing disproportionate costs for credit institutions.
Analytical Credit Datasets (AnaCredit)
ACCIS approach:
• Meetings and conference calls with Eurofinas, European Commission, ECB, and
relevant MEPs to generate support to ACCIS position paper
• Meeting request with the European Commission's Directorate General for
Competition (DG COMP) to assess the draft AnaCredit Regulation from an EU
competition law perspective
• Analysis and guidelines for ACCIS members on AnaCredit Regulation and
organisation of a webinar to present the content of the Regulation to the members
Latest Developments:
• The ECB, together with national central banks, is assessing the responses to the
consultation received from stakeholders
• An amended version of the draft regulation will be submitted to the ECB's
Governing Council for adoption not earlier than April 2016
Retail Financial Services Green Paper
10 December 2015 – EC published Green Paper Consultation on Retail Financial
Services and Insurance:
Relevance for ACCIS:
Among the subjects covered the Green Paper directly addresses the subject of credit
information, particularly:

The amount of data collected by credit bureaus and its relevance to
creditworthiness assessment;

Cross-border access to credit information to improve cross-border access to
credit;

Possible policy actions on credit registers to improve consumer protection and
provision of services.
Retail Financial Services Green Paper
State of Play and Next Steps
• 10 December 2015 – Publication of the Green Paper
• 10 December 2015 – 18 March 2016 – public consultation
• Q2/Q3 2016 - EC to present an Action Plan
ACCIS Activities:
• February-March 2016 – the PAWG prepared a response to the European Commission's
consultation
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with input from the wider membership
• 1 March 2016 – the PAWG organised a webinar on the Green Paper
• 2 March 2016 – ACCIS attended the Hearing organised by the EC on the Green Paper
ACCIS response to FSUG paper
• February 2016 – the Financial Services User Group (FSUG) published a position
paper on credit registers and credit data
• The Position Paper contains negative conclusions regarding the role of credit
register and credit data. In particular, the Position Paper concludes that:
1) Credit registers and the use of credit data do not help prevent overindebtedness;
2) Credit Registers and the use of credit data does not contribute to a better credit
at a more affordable cost;
3) There is no evidence that credit registers and the use of credit data help fulfil
prudential regulation objectives (better manage and hedge risks etc.).
ACCIS response to FSUG paper
The FSUG is an expert group set up to advise the European Commission on
consumer-related aspects of EU legislation and policy initiatives in the field of financial
services.
THEREFORE
Its conclusions and recommendations are likely to affect future Commission's policy
proposals relevant for the credit reporting industry.
ACCIS activities:
• The PAWG drafted a response presenting evidence-based arguments rejecting
the findings of the FSUG's position paper.
• The ACCIS response to the Position Paper will be submitted to the FSUG, the
European Commission and other relevant EU stakeholders in March 2016.
Capital Markets Union / Access to
Finance
• 18 February – 13 May 2015 – European Commission public consultation on
'Building a Capital Markets Union (CMU)'
• 30 September 2015 – European Commission published a CMU Action Plan
• Q1-Q2 2016 – mapping exercise on advisory capacities and pan-European
information systems
• Objectives of the CMU: to diversify financing sources; improve access to
finance (esp. SMEs); remove barriers to cross-border flows of capital
• Top political priority for the new EU Commission (Commissioner Jonathan Hill)
Capital Markets Union / Access to
Finance
State of Play
CMU Action Plan:
3 pillars regarding SME access to finance:
• Improving Banks' feedback to SMEs on rejected credit application
• Strengthening advisory capabilities (also public) directing SMEs to
alternative funding sources
• Developing informational infrastructures/platforms to matching SMEs with
finance providers
Commission's focus for the next months – discussions with banking
associations (feedback to SMEs) and 'mapping exercise' (advisory capabilities
and information infrastructure/platforms)
Capital Markets Union / Access to
Finance
ACCIS envisaged activities:
ACCIS objectives: improving information availability and sharing SME data and
making such data available on a reciprocity basis to alternative finance providers.
Clarify the distinction among different SME information (credit, trade credit, public,
other due diligence related info.)
•
Reach out to industry associations and MEPs engaged in CMU discussions in order to
get support
•
April 2016 - contact the European Commission to revisit the proposal for national
workshops on SME information (together with UEAPME).
•
Maintain regular contact with the European Commission's DG Financial Stability,
Financial Services and Capital Markets Union regarding the status of the actions
undertaken on SME access to finance.
Questions and Answers
Questions?
Follow-up
For further details, please contact:
•
Enrico Lodi: [email protected]
•
Valerijus Ostrovskis (ACCIS Secretariat): [email protected],
[email protected]
•
Federica Boledi (ACCIS Secretariat): [email protected],
[email protected]
THANK YOU!!!
ACCIS management restructuring
project - update
ACCIS Member Roundtable
22 March 2016,
Vienna
Neil Munroe, ACCIS President
Anne Keane, Director at Afore Consulting
Survey of members – main findings
• Purpose of survey
• Main findings
• Questions that arose
Afore Recommendations
•
To retain ACCIS role as a platform for the members to meet and share information.
•
To provide additional resources for the EU Public Affairs function.
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engagement in pro-active EU thought leadership in at least one policy area
agreement on a clear set of messages. The industry needs to speak with one
voice
Allocation of resources:
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60% of resources directly or indirectly allocated to the EU Public Affairs function
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40% of resources for the established networking activities.
•
Tiered membership: based on service offering and size of the individual member by
turnover and cross-border activity.
•
Tiering should be clear and transparent and be associated with additional services and
influence
Afore Recommendations
•
To hire an individual who would run the Secretariat of ACCIS (subject to the overall
resources available to ACCIS). This could be a part time role although the preference
would be for a full time position.
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Executive Committee and membership to agree on the profile of the individual to
run the Secretariat and initiate the recruitment process.
Individual to have sufficient expertise in Public Affairs engagement and
organizational skills to run the networking function of the association
Executive Committee and membership to decide the mandate of the Head of the
Secretariat (Public Affairs and networking goals, performance measurement
criteria, …)
The Head of the Secretariat to present to the Executive Committee a business plan
setting the budget against the association’s agreed mandate (based on the budget
parameters)
Afore Recommendations
Envisaged timeline

March 2016
ExCom to review the Recommendations and discuss whether they agree to
progress on this basis

Late May 2016
Second ExCom meeting to finalise position and present blueprint for the new
association

June 2016
General Meeting: blueprint to be formally presented to the membership

July 2016
Initiate recruitment of the Head of Secretariat

September 2016
Decision on the Head of Secretariat

November 2016
Head of Secretariat to take up position and present business plan

December 2016 to
February 2017
Transition from current to new Secretariat
Questions and Answers
Questions?
European Code of Conduct project
ACCIS Member Roundtable
22 March 2016,
Vienna
Neil Munroe, ACCIS President
European Code of Conduct project
• Objective: drafting of a European Code of Conduct for the industry to
explain to our stakeholders:
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who we are
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what we stand for
• Why: This will benefit the industry by increasing transparency and
streamlining some definitions and principles that are shared by all ACCIS
members.
European Code of Conduct project
• Actions taken:
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January 2015: Kick-off of the working group
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4 calls organised since the kick-off
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Allocation of responsibilities to each member of the group to draft
sections of the document
Next steps:
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The group aims at finalising the draft of the document before the Annual General
Meeting in June 2016
Presentation of the Code of Conduct at the AGM
The group is also considering the development of a Code of Conduct responding
to the requirements of the GDPR.
European Code of Conduct project
• Members of the working group:
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Neil Munroe (ACCIS President, Head of the Working Group)
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Mijo Brković (HROK, Croatia)
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Fabrizia Giacomini (Experian, Italy)
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Serena Holm (SCHUFA, Germany)
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Marta Liberda–Stembalska (KRD, Poland)
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Luisa Monti (CRIF, Italy)
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Vanessa Vijn (BKR, the Netherlands)
Cross-border Data Exchange
project
ACCIS Member Roundtable
22 March 2016,
Vienna
Luisa Monti, (CRIF) member of the PAWG
Cross-border Data Exchange project
Objective: revising the existing system of cross border data exchange (based on bilateral
agreements) and define a truly pan-European multilateral system under ACCIS umbrella
Why: on-going regulatory and policy context at the EU level demanding more and more
credit data sharing across the EU (e.g. AnaCredit and CMU)
Task: perform a feasibility assessment and establishing a detailed proposal on the
contents of the new cross-border data exchange system, including an implementation
plan with concrete actions and an estimate of costs of the project
Cross-border Data Exchange project
Actions taken:
•
Q4 2015: establishment of the Task Force in charge of developing the project
•
January 2016: kick-off of the project and establishment of sub-groups
•
February-March: organisation of work within the three sub-groups
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Legal: to investigate the legal and regulatory framework for the exchanging of
information among CRAs.
Data analysis: developing a proposal on harmonising the terminology and data
concepts used by the credit reporting industry across the EU.
Technical: technical feasibility and architectural structure of the data exchange
system.
Next steps:
•
Prepare a comprehensive document including proposals for implementation of the
project
Cross-border Data Exchange project
•
Members of the task force:
Head of the Task Force: Neil Munroe (ACCIS President)
Deputy Head of the TF: Luisa Monti (CRIF, Italy)
Sub-Group
Member
Company
Legal
Axel Bysikiewicz (L)
Schufa
Fabrizia Giacomini
Experian
Lucie Anna Melkova
CCB
Sándor Mikle
Bisz
Alessio Milani (L)
Crif
Sabine Malik
Schufa
Sean Hutchins
Experian
Safcsák Richárd
Bisz
Emanuel Venturi
Crif
Peter Strauss
Callcredit
Ivelin Nikolaev
Experian
Data Analysis
Technical
AGM & Conference 2016 and WCCRC 2016
update
ACCIS Member Roundtable
22 March 2016
Vienna
Jan Smith, Head of the Internal Member Management Work Stream
AGM & Conference 8-10th June 2016
•
Sheraton Hotel Lisbon
•
Conference website link on ACCIS website
•
Sponsorship opportunities available – Gala Dinner entertainment sold
•
17 registrations @ 17th March
WCCRC 25-27 September 2016
• Fairmont Royal York Hotel Toronto
• Pre-conference trip to Niagara Falls and local wineries
• Promotional campaign underway
• Website & Registration live 21st March
• Keynote speakers confirmed
• Global and digital agenda
• Sponsorship opportunities available
Questions and Answers
Questions?
ACCIS Member Roundtable
22 March 2016
Vienna