NEFI - Network of European Financial Institutions for SME (NEFI)


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Joint statement of AECM EAPB and NEFI on Financial Instruments - February 2012

Currently, the European Parliament is examining the EU Commission’s (EC) draft legal proposals for a new generation of financial instruments for the next programming period, notably the COSME and Horizon 2020. These proposals contain provisions for both guarantee and equity facilities aimed at addressing market failures in access to finance for small and medium-sized enterprises (SMEs) in the EU. Additionally, an increasing part of the funds under Cohesion Policy is planned to be used as financial instruments, and access to finance for SMEs is part of the scope of application.

NEFI statement on the Consultation of the European Commission’s ‘Green Paper’ for EU Research and Innovation - May 2011

NEFI welcomes the opportunity to take part in the public consultation on a Common Strategic Framework for EU research and innovation funding. We propose that a significant part of the budget allocated to the Framework be devoted to the innovation and SME domain, thereby bringing together all instruments and financial products able to cover the complete R&D and innovation cycle,

NEFI statement on the consultation on a possible successor to Competitiveness and Innovation Framework programm (CIP) - February 2011

NEFI appreciates the possibility to take part in the public consultation on a possible successor to the Competitiveness and Innovation Framework Programme (CIP), as some of
the NEFI members are important intermediaries of the CIP financial instruments.

Joint statement of AECM, EAPB and NEFI on Improving SMEs' access to finance in view of the financial , economic and social crisis - April 2010

NEFI comments together with the European Association of Mutual Gurantee Societies (AECM) and the European Association of Public Banks (EAPB) on adequate measures to keep up the access to finance for SMEs in view of financial, economic and social crisis.

NEFI statement on the Public consultation on Community innovation policy

NEFI welcomes the European Commission's communication "Reviewing Community innovation policy in a changing world".The experiences of NEFI members show that the allocation of EU funds could be improved to make the EU innovation policy more efficient and more effective.

NEFI Position Paper on How to Improve SMEs' Access to Finance in view of the Financial and Economic Crisis - January 2009

NEFI comments on "How to improve SMEs' access to finance in view of the financial and economic crisis". This position paper was presented at a High-Level Round Table Meeting organised by the European Commission, Directorate-General Enterprise and Industry, on January 21, 2009.

NEFI Comments on industry feedback on interbank exposures - June 2008

NEFI comments on the Capital Requirement Directive and the Banking Directive. NEFI underlines the importance of the interbank exposures for national promotional banks and shows the possible impact of the proposed changes.

NEFI statement on the European Commission’s Practical Guide to EU funding opportunities for research, development and innovation - April 2008

NEFI welcomes the European Commission‘s initiative for drafting a practical guide to EU funding opportunities for research, development and innovation. NEFI also appreciates the presentation of possible synergies in funding opportunities between the 7th Framework Programme for Research, the Competitiveness and Innovation Programme and the Structural Funds. Nevertheless, NEFI comments on several points, thereby trying to help making the guide more practical and helpful for possible users.

NEFI comments on the 3rd draft of the EU Commission General Block Exemption Regulation - March 2008

NEFI comments on the third draft of the General Block Exemption Regulation. Most of the issues raised in this NEFI statement had already been included in the first NEFI statement. Regarding the third draft, NEFI stresses again the way in which the cumulation of aid is handled, but comments also on other relevant topics.

NEFI Comments on 2nd draft revised Commission Notice on application of Articles 87 and 88 of EC Treaty to State aid in form of guarantees - March 2008

NEFI welcomes the changes made by the Commission in the second draft Notice. However, NEFI still considers that the present Commission draft has become a very complex document. Likewise, despite the amendments, NEFI considers that one problem which still exists is that, in particular for SMEs and hence also for start-up entrepreneurs and young entrepreneurs, the requirements planned in the draft notice are not appropriate.

NEFI Statement on the European Commission announcement to implement a Small Business Act for Europe in 2008 - February 2008

NEFI welcomes the announcement of a Small Business Act for Europe, and contributes some ideas which NEFI considers being important concerning the Access to finance for SMEs.

NEFI Comments on the application of articles 87 and 88 of the EC Treaty to State aid in the form of guarantees - October 2007

The new European Commission draft on the evaluation of State aid in the form of guarantees endeavours to increase transparency in the evaluation of State guarantees. This is essentially seen as a welcome move by the European Commission.

However, as a result the present European Commission draft has become a very complex document. In particular for SMEs and hence also for start-up entrepreneurs and young entrepreneurs, the requirements planned in the draft notice are, in our opinion, not appropriate.

European Commission Draft on the Community Guidelines for State Aid for Environmental Protection - June 2007

NEFI supports the Commission’s intention to revise the rules for granting state aid in favour of environmental protection in order to align them with the Community’s environmental and economic objectives. Against the background of climate change and shortage of natural resources, it is vital to support investments for environmental and climate protection. promoting this type of investments will ultimately contribute to increasing the competitiveness of companies in the EU as well.

2nd NEFI Statement on the EU Commissions Draft on the “Communication from the Commission on the revision of refernce rates" - June 2007

The European Commission has proposed a revision of the method for setting the reference and discount rates, and has taken up some of the critical issues raised by the Member States during the first consultation round in 2006. As the first draft, this second draft for a new reference rate system contains elements that were recommended in the study carried out by Deloitte & Touche in 2004 on behalf of the European Commission. Nevertheless, the Commission proposal does not yet sufficiently reflect the state of the art of lending and does not adequately take account of the market development

NEFI Statement on the EU-Commissions Draft Block Exemption Regulation - June 2007

With reference to the public consultation of member states and interested parties, NEFI has commented on the Draft Block Exemption regulation.

"5th Round Table of Bankers and SMEs" - May 2007

The European Commission organised in 2006-2007 a Round Table between representatives of banks and SMEs to discuss practices in SME finance in the EU. NEFI was one partner organisation within this process.

NEFI Statement on the EU Commissions Draft on the “Communication from the Commission on the revision of refernce rates" - November 2006

The reference rate system currently in place has repeatedly been subjected to criticism as it. However, the major advantage of the current system is that it can very easily be applied.

NEFI’ statement on the revised Commission proposal for an amended De minimis block exemption - November 2006

The Commission’s revised proposal for De minimis aid foresees a differentiation between transparent and non transparent aid measures. According to the Commission’s understanding promotional loans classify for transparent aid measures if they are backed by “normal security”.NEFI's comments in detail:

NEFI’ statement on the revised Commission proposal for an amended De minimis block exemption - October 2006

NEFI commented on the second draft of the Commission for an amended De minimis block exemption published 20 September 2006.

NEFI Statement on block exemption regulation on de minimis aid - May 2006

NEFI welcomes certain aspects raised in the Commissions proposal, e.g. to extend the scope of application and to increase the maximum for de minimis aid. In contrast all Partners entirely disagree with a number of severe modifications included in the above mentioned draft regulation. NEFI's comments in detail:

NEFI Statement on regional aid block exemption - April 2006

In February the Commission submitted a draft exemption regulation on regional investment aid.
NEFI welcomes the introduction of a block exemption regulation as it is likely to substantially
reduce the administrative effort required by the Member States for notification and shorten the
length of procedures (requiring only a summarized information in standardised form).
Specifically, NEFI's comments are as follows:

NEFI Statement on State Aid for Innovation - November 2005

As specialized financial institutions dedicated to the financing of SMEs, the Network of European Financial Institutions (NEFI) welcome the the European Commission´s proposals to allow better and more targeted State aid for innovation and to simplify the procedural regulations.

NEFI analysis "Financing innovation and research investments for SMEs" July 2005

The members of the Network of European Financial Institutions (NEFI) have designed and implemented promotional programs especially targeted at financing R&D projects of SMEs. The experience made by NEFI, the chalenges and problems in the field of innovation financing are topics of the analysis.