Consultation on review of directive 94/19/EC on deposit-guarantee schemes (DGS)

The European Commission has launched a consultation on the review of Directive 84/19/EC on Deposit Guarantee Schemes. The Central Chamber of Commerce of Finland submits the following statement for the consultation.

Question 1:Do you agree in general that the current framework of DGS in the EU needs to be revised? Are the areas identified for review the right ones, or are there other priorities?

We agree that the current framework of DGS needs to be revised and that the areas identified for review are appropriate. More harmonisation is clearly needed. Furthermore, there is a need for a common understanding on the basic features of the DGS, their role and their objectives.

The following options could be considered:

(a) Revert to a coverage of € 50 000

(b) Coverage of € 100 000 (current approach – from end 2010 onwards)

(c) Coverage of a higher amount

(d) Coverage depending on the actual size of deposits or economic indicators such as the Gross Domestic Product per capita (thus different in each Member State)

(e) Unlimited coverage

Question 2:Which of the above options would you prefer?

Question 3:Should the coverage level you prefer (Question 2) be a minimum or a fixed level?

Question 6:If the coverage level is fixed, should there be exemptions that allow a higher coverage of certain products for social considerations?

We prefer option a) revert to coverage of 50 000 Euros. The amount of coverage should be fixed. Furthermore, it is crucial that the coverage level is fully harmonised in the Member States. A fixed, harmonised deposit guarantee in the EU would contribute to the stability of the European financial market. It would also enhance the possibilities of cross-border activities.

We acknowledge that there is a need for exemptions for social considerations such as deposits of a sale price of a depositor’s home until a new home has been purchased within a reasonable time. However, exemptions from the fixed level of coverage should be harmonised.

Question 4:Do you have background information or evidence whether depositors have split up their deposits when the financial crisis aggravated in autumn 2008?

We have no statistics or other evidence. We have received some informal inquiries how the guarantee functions if deposits are split, so we assume that some depositors may have taken this precaution.

Question 10:Which solution(s) would you prefer as regards debt certificates?

Debt certificates are to be considered as investments and should not be covered by deposit guarantee.

Question 11:Which solution would you prefer as regards accounts in non-EU currencies?

Any Member State’s currency should be eligible for coverage but the maximum level should be determined in Euros.

Question 12:Should the eligibility criteria as regards depositors (provided for in Annex 1 no. 1-11 of the Directive) be fully harmonised or should Member States retain some discretion to decide about eligibility of depositors?

We support full harmonisation. In order to promote the internal market and depositors’ trust in the European financial sector and cross-border activities, it is important that the rules are the same in all Member States.

Question 18:Would you be generally in favour of a pan-EU DGS?

A pan-EU DGS is premature. At this point it is important to harmonise the different schemes.

• Lausunnon saaja: Euroopan komissio
• Lausunnon päivä: 22.7.2009
• Kirjoittaja: Leena Linnainmaa
• Titteli: Johtaja

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