The expertise possessed by fpmi's members makes our position papers and other materials sought-after sources of information on the issues of central importance to the financial sector.

Hot Topics

Enforcing digital fairness!

More and more transactions are intermediated through platforms that profit from network effects and that lead to the “tipping” of markets due to the “winner takes it all”-principle. Consumers make their choices for private consumption with the help of search engines and comparison platforms – if their decision has not yet been taken by digital assistants such as Amazon’s Alexa. The real suppliers, i.e. the companies providing the goods and services that the consumer ultimately seeks to have, lose access to the consumer. The competition of these suppliers, traditionally seen as a central driver of the market economy, is pushed to the periphery of the platform. The expert opinion at hand provides impulses for the current attempts in the European Union to create a regulatory framework for digital marketplaces.

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fpmi Opinion: Innovation, Variety & Fair Choice

The digitalisation has unleashed enormous potential, reduced transaction costs, enhanced consumer welfare and inspired a new entrepreneurial culture. New technologies and business models lead to a far-reaching modernisation of business.

Notwithstanding the dynamics of digitalisation, the economy is at a turning point: Its fundamental infrastructure is being transformed. Some platforms turn into gatekeepers of the market places of the digital economy. Due to network effects, economies of scale and superior access to data, the success of such platforms becomes self-reinforcing. In a platform economy competition is for the market – not on the market. Markets may be “tipped” and are organised and governed by one or two platforms only.

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European Supervisory Authorities - Room for improvement at Level 2 and Level 3

On behalf of the fpmi the Centre for European Policy (cep) has examined the regulatory role of the European Supervisory Authorities (ESAs) and the EU Commission and produced an Analysis. Cep makes ten recommendations for improving control and scrutiny of the ESAs' activities at Level 2 and Level 3. These recommendations will help to ensure that the ESAs and the Commission comply with four essential principles when carrying out their regulatory work: adherence to the mandate, subsidiarity, proportionality and consistence.

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Munich Financial Centre Initiative Position Paper on the occasion of the visit to Brussels on October 14th/ 15th, 2015

Table of contents

1. The EU´s capital markets union and how it would impact upon SMEs
2. Basel III follow-up regulations
3. Reform of bank structures - banks segregated by activities
4. Deposit security in Europe
5. Ramifications of digitalization

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Financing the Real Economy in the Capital Markets Union Era - Recommendations for Policy Action

Report commissioned by the Munich Financial Center Initiative (FPMI)

This report deals with the significance of the Capital Markets Union (CMU) for corporate finance. It begins by evaluating the status quo with regard to capital market-oriented and bank-based corporate finance in Germany. The subject matter and background of the CMU are then illuminated and the CMU is subjected to a qualitative analysis. The last section of the assessment features recommendations for action derived from the analysis.

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Munich Financial Center Initiative rejects financial transaction tax

The Munich Financial Center Initiative (known by its German acronym of “fpmi”) supports the basic objective of the Commission, which is to hinder “undesirable speculation”. The Initiative wants to make its position very clear. This objective will not be attained by the proposed TFT.


This rejection is substantiated by the following points:
1. Encumbrance of private and corporate pension plans and of small-scale investors
Lessening of the attractiveness of investments in securities affected by the TFT through extraterritorial application
Impairment of the supply of credit to the business community
Increasing of the costs of capital borne by companies and thus impairing equity financing
Restricting the market makers’ function of assuring the market of having liquidity


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fpmi issues appraisal of Solvency II and Basel III

fpmi issues appraisal of Solvency II and Basel III

"“Solvency II” and “Basel III” could give rise to substantial risks to the financing of German companies, should the mutually reinforcing effects of these regulatory reforms in the insurance and banking sector not be taken into account.

1. Executive Summary
2. Introduction
3. Solvency II and asset allocation in the insurance sector
4. Insurers and corporate financing
5. Reform of bank regulation and alterations in the refinancing of the banking sector
6. Ramifications upon corporate financing "

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fpmi's position on the occasion of their visit to Brussel on February 2nd, 2011

The financial industry's hotly discussed issues – fpmi's expert positions

"The financial industry's central issues are the subject of hot discussion. fpmi has compiled thoughtful and expert positions on them.

Content of the paper:
1. Solvency II
2. Insurance guarantee systems
3. Green Paper on pensions
4. CRD IV / Basel III; cumulative ramifications of regulations currently being enacted
5. The regulation of financial markets: encumbrance for the real economy
6. Revamping of MiFID
7. Regulation of OTC derivatives (draft regulation)
8. Regulation of short selling"

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Better than more regulations

According to the fpmi, comprehensive provisions are needed in order to permanently stabilize international financial markets and to prevent a new financial crisis. The measures needed should include regulations of markets and financial corporations as well as comprise other aspects, such as consumer protection.

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Best execution in securities trading not implemented in best interests of investors

The EU Commission’s best execution requirements were enacted to ensure private investors of having optimal access to securities traded on exchanges. The faulty implementation of the regulations has however given rise to negative developments. Affected by these are investors.

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Sales of credits: the position taken by associations of banks

The German government is considering enacting regulations on the sales of credits by banks. These possible regulations would be partially counterproductive, as they would yield no net benefits to either the issuers or to the recipients of credits. This is the position (in German) taken by the associations of banks participating in the Munich Financial Center Initiative (mfci).

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fpmi: Revisions required in corporate tax reform

Taking effect on January 1, 2008, Germany’s corporate tax code contains several key provisions requiring revision, maintains Munich Financial Center Initiative (fpmi).

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International-level code regulating operations of hedge funds required

Munich Financial Center Initiative (fpmi) views the ever-growing influence of hedge funds upon the financial and business communities as posing a danger to the international financial markets’ stability. For this reason, an international-level code regulating the operations of these funds needs to be enacted, believes fpmi.

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The Bank Account Attachment Act: judicial responsibilities have to remain the bailiwick of courts of law

Munich Financial Center Initiative (fpmi) maintains that the objective of the proposed reform of the Bank Account Attachment Act should be the maximum possible reduction of the complexity of the bank account attachment procedure experienced by all parties involved.

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Time allocated for implementation of MiFID is too short

Germany’s government should not use its plans to incorporate the EU’s Markets in Financial Instruments Directive (MiFID) into Germany’s body of legislation as an occasion to enhance the powers enjoyed by Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin – Germany’s Agency for the Supervision of Financial Services) by curtailing the independence of operation accorded to the country’s securities.

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Bureaucracy costs billions

"The costs incurred by Germany’s banks from administrative operations decreed by the state amount to more than €3 billion a year.

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Reform of corporate tax code: Good intentions shouldn’t be thwarted

The members of Munich Financial Center Initiative (fpmi) are in favor of a corporate tax reform of lasting impact. The reduction in nominal tax rates will however only achieve its goal should it lead to a substantially-large cut in the amount of taxation paid by corporations. This goal could be foiled by an accompanying and comprehensively-large broadening of the base of tax assessment.

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Revamping of insurance contract act has to be reconsidered

The draft of the insurance contract act (ICA) does have several productive provisions, believe the insurers and several other members of the Munich Financial Center Initiative (fpmi).

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fpmi: efficacious structure needed for final withholding tax

Germany’s government resolved in July to introduce a final withholding tax on capital investments. Munich Financial Center Initiative views the move as being a step in the right direction.

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fpmi calls for no-delay authorization of REITs

The Munich Financial Center Initiative is calling for the authorization of real estate investment trusts (REITs) by the beginning of 2007 in Germany.

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Make consumer credit directive accord to real-life conditions

Munich Financial Center Initiative (mfci) views the second draft submitted by the EU Commission of the consumer credit directive as containing key points still requiring improvement.

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Presentation of the fpmi in Brussels on February 1st, 2006

Bavaria's Economics Vice-Minister Spitzner on a visit to Brussels with the Munich Financial Center Initiative / Regulatory pause called for in the financial sector. Spitzner: "No overregulation for the financial sector".

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Reduce over-regulation of financial markets

The thicket of financial market regulations constitutes a great encumbrance upon the members of Bavaria's financial community, whose viability is impaired by it. This damages the economy as a whole.

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fpmi members support small and medium-sized companies

Small and mid-sized enterprises employ approximately 75% of all workers and over 80% of apprentices in Bavaria. In addition, they are responsible for about 65% of the value added by Bavarian companies. The Bavarian state government has developed a four-pronged approach: improving the tax framework, conditions for participant and loan financing, and enhancing the overall economic environment.

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