Response to discussion Paper and Call for Evidence on SMEs and the SME Supporting Factor
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Q2: In your experience, is the reduction in capital requirements due to the application of the SME Supporting Factor (capital relief) being used to support lending to SMEs? Yes/No. Please explain and provide evidence.
Yes, see VDB Position paper, attached.Q5: Do you see merits in having a harmonised definition of SMEs for reporting purposes? Yes/No. Please explain and provide specific examples.
Yes, see VDB Position paper, attachedQ8: In your experience, are SMEs as cyclical or more/less cyclical than large enterprises?
Yes, see VDB Position paper, attachedQ14: In your experience, is there an impact of the SME supporting factor on the volume of SME lending compared to other loans? Yes/No. Please explain and provide evidence.
Yes, see VDB Position paper, attachedQ15: In your experience, is there an impact of the SME supporting factor on the pricing and overall conditions of SME lending compared to other loans? Yes/No. Please explain and provide evidence.
Yes, see VDB Position paper, attached.Q16: Do you consider SMEs are a consistent group when it comes to access to credit or should a distinction be made between different types of SMEs (e.g. micro, small and medium ones)? Yes/No. Please explain and provide specific examples.
No, see VDB Position paper attached.Upload files
VDB_Position_EBA_SME_Factor_english.pdf
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