Simon Lewis, Chief Executive of the Association for Financial Markets in Europe, today issued the following comment on the report of European Commission’s High Level Expert Group on banking reform: “We will study with interest the recommendations of the High‐Level Expert Group and we note Commissioner Barnier’s comment today that he will consider their impact on growth and the safety and integrity of financial services. European banking is already undergoing profound change as a result of regulatory reform and of shifts in market fundamentals. It is not at all clear that further structural reform would make the system safer or more efficient. “AFME supports the regulatory reform programme and the authorities’ aim of restoring confidence in the European financial system. But we do not believe that further changes to the structure of the banking industry are necessary or will contribute to Europe’s economic growth.” ‐ENDS‐

The Association for Financial Markets in Europe (AFME) has appointed regulatory expert and academic Eddy Wymeersch as a nonexecutive director and senior advisor. Mr Wymeersch was formerly chair of the Committee of European Securities Regulators (CESR) as well as the Chairman of the Supervisory Board of the Belgian Banking, Finance and Insurance Commission. He will join the AFME Board with immediate effect, following the Association’s Board meeting and Annual General Meeting, which took place on 19 September 2012. He is currently chairman of the Public Interest Oversight Board in Madrid and member of the board of Euroclear. He was a member of the European Corporate Governance Forum, an advisor to the Belgian Government, the European Commission and international institutions. He teaches on company law, banking law and securities regulation. Gaёl de Boissard, AFME’s chairman commented: “Europe’s capital markets are experiencing unprecedented levels of regulatory change and we are delighted to appoint someone with Eddy Wymeersch’s enormous experience of the financial markets to our Board. His expertise and understanding of the role of European policymakers, in particular, will be invaluable to us as an advisor.” Eddy Wymeersch commented: “I hope that my expertise in the financial field will benefit AFME and its members and contribute to the integration of the financial markets in Europe and worldwide. At the present juncture when so many issues are popping up, it will be necessary to develop a long-term view to stabilise the system and contribute to the growth of our economies.” ‐ENDS‐

AFME welcomes the Commission’s expanded approach to the review of Solvency II capital charges. Long term financing of the EU is an important objective and has been identified as an important consideration in the determination of capital charges of certain assets, including securitisations. We believe securitisation will need to continue to play an important role in the long term financing the real economy. The letter from Jonathan Faull, Director General Internal Market and Services, to Gabriel Bernardino, Chair of EIOPA, asking him to revisit the capital charges on securitisation, is now on the website of the European Commission at the following link: http://ec.europa.eu/internal_market/insurance/solvency/latest/index_en.htm

Commenting on the European Commission’s proposal for a European banking union, issued today, Simon Lewis, the chief executive at the Association for Financial Markets in Europe (AFME) said: “We welcome the Commission’s proposal as a vital step towards restoring confidence in Europe’s financial system and wider economy. “Creating a strong banking union, built around a credible and effective single supervisor, should break the link between the solvency of Europe’s banks and its sovereigns, which has been a significant cause of instability in recent years. “Some key issues remain to be resolved, including the implications for the Single Market; the allocation of responsibilities between the ECB and national supervisors within and outside the banking union; and the essential backstop arrangements for resolution and depositor protection. We stand ready to assist policymakers in working through the issues.” -ENDS-

Simon Lewis, Chief Executive of the Association for Financial Markets in Europe, today issued the following statement on the initiative by 11 EU member states to introduce a Financial Transaction Tax: “The initiative by 11 EU member states to introduce an FTT is regrettable. It is likely to serve as another brake on economic growth, it is a highly inefficient way of raising tax, and given the negative impact on growth it could even reduce overall tax revenues in net terms. ” ‐ENDS‐

The proposed Financial Transaction Tax (FTT) would not only reduce economic activity but would also be a highly inefficient way to raise public funds, even on the European Commission’s own assumptions about revenues likely to be raised and potential costs incurred, according to a new report from the independent economic consultants Oxera. The Commission’s assumptions concerning the proposed FTT show that the ratio of GDP lost to tax revenue gained as a result of the tax could range between 2:1 and 4:1, says Oxera. But even this is likely to be a serious under‐estimate, as reduced economic activity resulting from the tax would be expected to reduce other sources of tax revenue. Because of these effects, Oxera estimates that the real ratio of GDP loss to overall tax revenue gained could be as high as 10:1, and it restates its comment in a previous report on the FTT published in December 2011 that there is a risk that imposition of the tax could actually reduce overall tax revenues from the economy rather than raising additional revenue. The latest Oxera report was commissioned by the Association for Financial Markets in Europe and other associations[1] after the European Commission published a further analysis of the macroeconomic impact of the FTT using a new economic model. It comes amid renewed discussion of the tax by European Union finance ministers in the context of the eurozone sovereign debt and banking crisis. The Commission’s latest analysis, published in the form of seven explanatory notes on May 4, contains different estimates for the economic impact of the tax from those contained in the economic impact assessment included with the original FTT proposal last year. The explanatory notes state that the FTT is expected to reduce annual real gross domestic product by 0.28 per cent in the long term. However, Oxera argues these new estimates significantly underestimate the negative GDP impact as the Commission is ignoring a whole range of effects of the tax, for example on investment financing. Simon Lewis, Chief Executive of AFME, commented: “We have always said that the FTT is a flawed idea, which is likely to have serious negative repercussions for the European economy. We are also concerned that the political discussions on the subject are taking place without sufficiently rigorous economic analysis. This report confirms that much more debate is needed about the meagre gains expected from this tax and the significant damage it would cause to savers, investors and companies.” -ENDS‐

The Global Financial Markets Association (GFMA) today released the following statement from Simon Lewis, chief executive, in response to financial reform developments within the G20 Communiqué issued on 19 June 2012. “We welcome the G20’s continuing focus on reforming the financial sector, which has already led to significant regulatory change, including robust capital and liquidity requirements for banks and a framework for an international resolution regime. ”We also welcome the commitment of the G20 leaders to maintaining a consistent and coherent global approach, which is becoming ever more important as leading countries and regions create an increasingly complex regulatory environment. As G20 ministers continue to implement the reforms necessary to ensure a robust global financial system, we would urge them to thoroughly assess the impact on economic growth of the numerous initiatives underway in several jurisdictions.” Additional GFMA commentary on specific areas of financial reform: Legal Entity Identifiers (LEIs) “The FSB should be commended for recognizing the need for a strong central control process to ensure integrity of information in the LEI database. GFMA fully supports the establishment of a global LEI system, which could dramatically improve systemic risk management in the global financial industry. However, if the Implementation Group is to comprise only regulators, then GFMA would like to see active interaction with industry experts to ensure the system is set up in a timely and effective way. GFMA supports the FSB call to launch the LEI system by the end of this year and to be independently operational by March 2013. As the LEI system rolls out, we encourage the FSB and global regulators to utilize the industryendorsed prototype LEI utility (as provided by DTCC and SWIFT). This utility operates on a costrecovery basis and provides data that is freely available to all users, without redistribution or licensing fees.” Compensation “GFMA is concerned about proposals to set legal caps on variable compensation since it believes that attempts by legislators to set a maximum ratio between fixed and variable compensation intrudes on the important role of shareholders to determine key questions on pay and commercial strategy. Moreover, regulation should be designed to aid financial stability and economic growth. This proposal could introduce additional fragility to the European banking system by increasing banks’ fixed costs. GFMA believes that this issue requires further debate and hopes that an opportunity for this will emerge from further negotiations. “ Strengthening the Financial Stability Board “GFMA strongly supports reinforcing the role of the Financial Stability Board which will allow it to play an enhanced role in co-ordinating and harmonizing global financial regulation. Given the FSB’s enhanced role, we appreciate their recognition that there needs to be increased consultation and transparency with the private sector. This is particularly important as the growing complexity of international financial regulation could impact not only market participants, but also regulators and supervisors.” Capital Requirements “GFMA supports the strengthening of capital and liquidity requirements under the Basel III accord, and calls on the FSB to ensure the new framework is rolled out in a measured and consistent way around the globe and with consideration to the delicate balance between maintaining robust capital requirements and the ability for banks to support economic growth.” Oil Price Reporting Agencies (PRAs) “PRAs have a significant impact on derivatives and physical oil worldwide as they play an important price discovery role in oil markets and their published prices have a material impact on price formation in a market which includes financial activity. As such, we believe PRAs need to be subject to a clear and transparent regulatory framework that provides consistent treatment with similar price formation services or providers in other product areas. In addition, if PRAs are providing material execution services in a market and those services are financial in nature, they need to be subject to a regulatory framework that is consistent with those applied to other like services.” -ENDS-

The Association for Financial Markets in Europe (AFME) and the European Financial Services Round Table (EFR) today announced the launch of Prime Collateralised Securities (PCS) ‐ an industry‐led, nonprofit project to develop a label for high quality securitisations which meet best practice in terms of quality, transparency, simplicity, and standardisation. With the first label expected to be granted by the PCS Secretariat towards the end of this year, a number of key milestones have been reached: establishment of the PCS Association and the PCS Secretariat as bodies to respectively govern and operationally administer the PCS label; the appointment of the Head of the PCS Secretariat; identification of asset classes and structures which are eligible and not eligible for the label; compliance with required loan by loan reporting standards of the ECB and Bank of England; the fundraising target was fully achieved. Access to securitisation markets for issuers is becoming increasingly important to overcome a real economy funding shortfall1 in Europe. Asset Backed Securities can be an important component of the instruments that investors have available to them, especially as they do not use up the same credit line capacity as other investments, such as corporate bonds and covered bonds. Yet, despite the very strong underlying performance of European asset backed securities since 2007, a smaller investor base and the reduced level of issuance over this period could have knock on effects for companies reliant on capital markets funding, as well as Europe’s broader economic recovery. The PCS initiative ‐ developed by a broad group of market professionals comprising issuers, investors arrangers, and other market participants, in collaboration with other European industry associations, as well as observers such as the European Central Bank, European Investment Bank and Bank of England ‐ will comprise a two‐tier governance structure: a PCS Association, comprising independent non‐industry directors, as well as a mix of industry professionals; a PCS Secretariat, led by experienced industry professional Ian Bell, responsible for the day‐to‐day administrative and managerial operations. The PCS Secretariat will grant the PCS label to securities, certify a transaction and monitor the label after it is issued. Recent estimates show that €650 billion of senior unsecured and covered bond funding will mature in 2012 for European banks; for sovereigns, funding of over €900 billion will be needed and that an additional €1.5 – €1.9 trillion of funding will be needed to power any growth. Sources: Bloomberg and BAML Global Research Dec 2011, Standard & Poor's May 2012. PCS is more than just a positive label for eligible securitisations – it provides the basis for a definition of agreed market standards, as well as an enforcement mechanism of these agreed standards, based on a label which can be granted and withdrawn depending on compliance and as verified by the PCS Secretariat. Rick Watson, Head of Capital Markets at AFME, commented: “Investors and regulators need a clear reference point, setting out best practices around which to build investment guidelines and regulations, which, in turn, will encourage issuance as well as investment and support the real economy. Combining the expertise and market coverage of both AFME and EFR members has resulted in the ability to move forward on this very important initiative. “PCS will bring added quality, transparency and standardisation to the market, which will deepen the securitisation investor base in Europe and, in turn, improve overall liquidity. Europe needs a healthy securitisation market and we are confident that this initiative, alongside regulatory changes, will provide a significant boost to the market.” Sebastian Fairhurst, the EFR’s Secretary‐General, commented: “The PCS label will be awarded on a deal‐by‐deal basis and subjected to a verification process by the newly established PCS Secretariat. It will be granted to transactions backed by asset classes that have performed extremely well through the financial crisis and are of direct relevance to the real economy, including European auto, residential mortgage, SME, consumer and credit loans. “Issuers will need to provide high quality reporting on an ongoing basis, in accordance with the relevant ECB and Bank of England reporting standards.” Ian Bell, PCS’s newly appointed Head of Secretariat, commented: “It’s exciting to be part of such an important industry initiative, which has seen so much support from investors, issuers and policymakers alike. With commitments to fully fund PCS’ first two years of operations from over 30 institutions in the industry, PCS demonstrates the seriousness of the industry’s intent to establish a vibrant, yet robust European securitisation market capable of funding the growth Europe so badly needs." ‐ENDS‐

I am writing on behalf of AFME (the Association for Financial Markets in Europe) to respond to the Accounting Standards Board’s (“the ASB’s”) January 2012 Financial Reporting Exposure Drafts on the future of financial reporting in the UK and Republic of Ireland (“the FREDs”). AFME is, as you know, the leading European trade association for firms active in investment banking and securities trading and thus represents the shared interests of a broad range of participants in the wholesale financial markets. We welcome the opportunity to respond to these latest FREDs, and we commend the ASB for its continued consultation on this important topic. As noted in our letter of 21 April 2011, in which we commented on the ASB’s previous UK GAAP proposals, the great majority of AFME members are large financial institutions with trading operations in a significant number of countries, both inside and outside the EU, and securities listed on one or more exchanges. Their interests therefore focus on only certain limited sections of the proposals, and this is reflected in our comments below. As explained in our responses to Questions 1 and 2, a key concern with the current proposals is the exclusion of financial institutions from the exemption for financial instrument disclosures. Given, amongst other factors, the focus of users on consolidated financial statements (which is acknowledged in the FREDs) we believe the disclosure exemptions should be applied consistently to all wholly owned subsidiaries, provided that the relevant information is presented in publicly available consolidated financial statements that include the entity concerned. Moreover, as financial institutions that are wholly owned subsidiaries are currently eligible for exemption from the financial instrument disclosures in FRS 29 (IFRS 7): Financial Instrument Disclosures, we believe the present proposal provides an unnecessary element of “gold plating” in this respect, which contravenes the principle set out in sub-paragraph 3.11(c) of Part One of the FREDs. Association for Financial Markets in Europe St. Michael’s House, 1 George Yard, London EC3V 9DH, United Kingdom T: +44 (0)20 7743 9300 F: +44 (0)20 7743 9301 www.afme.eu Company Registration No: 6996678 European Union Register of Interest Representatives No: 65110063986‐76 Our responses to the questions set out on pages 9‐10 of Part One of the FREDs are set out below. Q1 The ASB is setting out the proposals in this revised FRED following a prolonged period of consultation. The ASB considers that the proposals in FREDs 46 to FRED 48 achieve its project objective: To enable users of accounts to receive high­quality, understandable financial reporting proportionate to the size and complexity of the entity and users’ information needs. Do you agree? A1 We support the stated project objective, which we believe is generally achieved by the proposals. We note in particular that the proposal acknowledges that users generally focus on the consolidated financial statements rather than those of wholly owned subsidiaries, and that the proposals therefore provide reduced disclosure requirements for wholly owned subsidiaries, an approach which we support. As already stated, however, we believe this principle should be consistently applied, and that wholly owned subsidiaries that happen to be financial institutions should also be permitted to use the exemption from financial instrument disclosures since this information will be available for users in the consolidated group financial statements. We note also that financial institutions that are wholly owned subsidiaries are currently eligible for exemption from the financial instrument disclosures contained within FRS 29, and we are not aware of any user demand for these disclosures to be provided at the individual legal entity level. On this basis, we believe the existing exemption should be retained in the ASB’s revised reporting requirements. Q2 The ASB has decided to seek views on whether: As proposed in FRED 47 A qualifying entity that is a financial institution should not be exempt from any of the disclosure requirements in either IFRS 7 or IFRS 13; or Alternatively A qualifying entity that is a financial institution should be exempt in its individual accounts from all of IFRS 7 except for paragraphs 6, 7, 9(b), 16, 27A, 31, 33, 36, 37, 38, 39, 40 and 41 and from paragraphs 92­99 of IFRS 13 (all disclosure requirements except the disclosure objectives). Which alternative do you prefer and why? A2 As already noted, we believe the reduced disclosure framework should be applied consistently to all entities, including financial institutions, given the focus of users on consolidated financial statements and the existing availability of this exemption to financial institutions under FRS 29. Notwithstanding the above, we believe the first of the stated alternatives ‐ the FRED 47 proposal ‐ will be clearer and easier to apply. Q3 Do you agree with the proposed scope for the areas cross­referenced to EU­adopted IFRS as set out in section 1 of FRED 48? If not, please state what changes you prefer and why. A3 We do not believe our members will be significantly affected by this aspect of the proposals and therefore have no comment on this question. Q4 Do you agree with the definition of a financial institution? If not, please provide your reasons and suggest how the definition might be improved. A4 While in general supporting the definition of a financial institution, we note that it appears, as currently drafted, to exclude broker‐dealer entities. As the nature of broker‐dealer activities is consistent with that of institutions included in the scope of the proposed definition, we believe it would be appropriate for broker‐dealers also to be included. We understand from your colleagues that it is the ASB’s intention to clarify/amend the FREDs so as to ensure that broker‐dealer entities fall within the definition of a financial institution, and we would therefore support such a change. Q5 In relation to the proposals for specialist activities, the ASB would welcome views on: (a) Whether and, if so, why the proposals for agriculture activities are considered unduly arduous? What alternatives should be proposed? (b) Whether the proposals for service concession arrangements are sufficient to meet the needs of preparers? A5 Our members will not be affected by these aspects of the proposals and we therefore have no comment on this question. Q6 The ASB is requesting comment on the proposals for the financial statements of retirement benefit plans, including: (a) Do you consider that the proposals provide sufficient guidance? (b) Do you agree with the proposed disclosures about the liability to pay pension benefits? A6 Our members will not be affected by the proposals for the financial statements of retirement benefit plans (at least in relation to their role as AFME members), and we therefore have no comment on this question. Q7 Do you consider that the related party disclosure requirements in section 33 of FRED 48 are sufficient to meet the needs of preparers and users? A7 We believe the disclosure requirements in section 33 of FRED 48 should be sufficient to meet the needs of both preparers and users. In particular, we support the ASB’s decision to retain the existing exemption from the related party disclosure requirements for transactions between wholly‐owned members of a group. In our view, disclosure of such transactions adds little if any useful information at the subsidiary level. The volume of such transactions can however be significant, making it onerous for preparers to collect the relevant information, and we therefore believe any benefit to users from providing such disclosures will be far outweighed by the cost to preparers of producing the information. Retaining this exemption is also consistent with the focus of users on the consolidated group financial statements as transactions between members of a wholly owned group will be eliminated on consolidation. Q8 Do you agree with the effective date? If not, what alternative date would you prefer and why? A8 While sympathetic to the conflicting demands on the ASB in regard to introducing the proposed changes, we remain concerned that the proposed effective date may not be realistic given the major changes currently being developed in IFRS, particularly in relation to those standards that may have significant operational impacts, such as impairment of financial assets and leases. As noted in our letter of 21 April 2011 on the ASB’s previous proposals, it is difficult to determine operationally how the ASB’s proposed effective date will impact the implementation efforts of preparers when the IASB has still not finalised the effective dates for all of its new standards. We therefore recommend that the ASB should reconsider the effective date for its current proposals once the IASB has determined the implementation timetable for its own new standards. Q9 Do you support the alternative view, or any individual aspect of it? A9 We do not support the alternative view. Although we believe its stated objective to be broadly consistent with the ASB’s stated objective, we think many of the points made in respect of complexity would be more appropriately addressed specifically to entities which report under the FRSSE, rather than to the broad range of companies at which the FREDs are directed. We also believe that introducing alternative accounting methodologies, formats and treatments adds complexity, and would undermine the key objective of introducing a consistent accounting framework for all companies reporting under UK GAAP.

Q: Can you outline what proposals have been issued earlier this week by the Federal Deposit Insurance Corporation (FDIC) and Bank of England paper? The US Federal Deposit Insurance Corporation and the Bank of England issued a joint paper entitled ‘Resolving Globally Active, Systemically Important Financial Institutions’ which discusses how UK and US regulators plan to deal with global systemically important financial institutions – or G‐Sifis ‐ that fail across the two jurisdictions. The paper focuses on ‘top down’ resolution strategies that involve a single resolution authority applying its powers to the top of a financial group – that is, at the parent holding company level – while keeping bank, securities and other operating subsidiaries out of resolution, insolvency or administration. These strategies are designed to solve the ‘too big to fail’ problem by providing an alternative to the toxic choice between taxpayer‐funded bailouts and liquidations that can destabilize the financial system. The broader goal is to produce resolution strategies that can impose losses on a firm’s shareholders and debtholders, rather than taxpayers, while maximizing the group’s franchise value and maintaining its systemically important operations. This will provide a credible alternative to the toxic choice between taxpayer bailouts and destabilization of the financial system. Q: What’s the significance of these proposals? Ever since the collapse of Lehman Brothers and the bailout of AIG and other firms four years ago, policymakers have been debating how best to develop a resolution framework that will effectively deal with a failing institution without a destabilizing liquidation like Lehman or a bailout like AIG. In light of the fact that 12 of the world’s 28 G‐Sifis are based in the UK or US, this paper is a major contribution to that debate. Q:o you agree with the approach taken in the paper? Yes, we strongly agree with top‐down resolution strategies, when they are appropriate. They can be effective in resolving most G‐SiFis by imposing the losses of the G‐SiFi on its shareholders and debtholders, instead of taxpayers, while maximizing its franchise value and preserving the systemic operations of its operating subsidiaries. There has been some press comment suggesting that GFMA is not supportive of the top down approach to resolving G‐SiFis. However, this is categorically not the case. GFMA strongly supports the joint paper – our members believe that no financial firm should be ‘too big to fail’ or have to rely on taxpayer support for its survival. The paper provides a helpful explanation of the approaches that each of the US and UK authorities would take to resolution of G‐Sifis via a single point of entry route. Although the main focus of the paper is on a ‘single point of entry’ resolution approach, the joint paper itself acknowledges that the US and UK would apply different versions of this approach because of the differing legal structures and funding approaches of their G‐SiFis. It also points out that the top‐down approach may “not necessarily be appropriate for all UK G‐SiFis in all circumstances. Other strategies may be more appropriate depending on the structure of the group, the nature of its business, and the size and location of the group’s losses.” We agree with this qualification as much as we agree with top down strategies, when they are appropriate. In other words, as we pointed out in our recent comment letter on the Financial Stability Board’s Consultative Document on Recovery and Resolution Planning, we do not believe that one size fits all financial firms. Different resolution models or ‘presumptive paths’ may be necessary, depending on a firm’s corporate structure, size, complexity, funding structure, or other characteristics or circumstances. Q: So you think resolution authorities should have some flexibility in their approach? Yes, although as we pointed out in our recent comment letter to the FSB, we think that pre‐vetted resolution strategies are necessary to provide host‐country regulators, depositors, creditors, equity holders, counterparties and financial market infrastructures, among others, with a reasonable degree of confidence of how a particular G‐SiFi will be resolved in a failure scenario. As the joint FDIC / Bank of England paper acknowledges, resolution authorities need some flexibility to deviate from the ‘presumptive path’ in order to adapt to particular circumstances at the time of a particular firm’s failure. The development of firm‐specific cross‐border cooperation agreements will be a key component to achieve the right balance between predictability and flexibility. Any bilateral agreement between the UK and US could act as a framework for and supplement to individual firm specific cross‐border cooperation agreements. Q: How does the joint paper fit in with the other resolution programmes in development at G20 and European level? Importantly this joint paper is set against the framework established by the Financial Stability Board (FSB) and is consistent with the FSB’s Key Attributes of Effective Resolution Regimes for Financial Stability. GFMA views the proposals as being in line with FSB, European Union and US resolution laws. Q: What are next steps? The proposals in the joint FDIC / Bank of England paper are likely to be discussed further with a view to developing cross‐border cooperation agreements. In addition, we believe policymakers in other jurisdictions will be examining the proposals contained in the paper with great interest.