Nous ne savons pas si la réponse la plus récente à cette demande contient l'information ou non – si vous etes Paul Schreiber veuillez vous connecter et laisser nous savoir.

Dear European Central Bank,

In January, the ECB launched the review of its monetary policy strategy. Due to the Covid crisis, the review was postponed and should be conducted by mid-2021. One of the main objectives of the review is to evaluate the effectiveness and potential side effects of the monetary policy conducted by the ECB. To reach this objective, a complete knowledge of the use of unconventional monetary operations is needed.

Today, the ECB discloses the corporate bonds it holds under the CSPP and the PEPP and the total value of its purchase under these programs. However, the ECB doesn’t disclose the value of each separate bond held under the CSPP and PEPP.

Despite the fact that the “greening” of the APP is one of the strategic orientations that have to be discussed during the strategic review, the non-disclosure of bond value makes it impossible to know what CSPP and PEPP finance and, therefore, to determine their environmental impacts. Amid the Covid crisis, the non-disclosure of bond value conceals the amount of financing that PEPP provides to critical sectors such as healthcare.

Given these elements, under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the separate bond value of CSPP and PEPP assets held by the ECB and the Eurosystem.

Yours faithfully,

Paul Schreiber

Campaigner on the Supervision of Financial Actors
Reclaim Finance

Access to documents,

Dear Mr Schreiber,

Thank you for your request, which we have received on 22 April 2020, for
access to European Central Bank (ECB) documents.

In accordance with [1]Decision ECB/2004/3 on public access to ECB
documents, as last amended, you will receive a reply within 20 working
days.

Yours sincerely,

Compliance and Governance Office

DG Secretariat

European Central Bank

Sonnemannstrasse 20

60314 Frankfurt am Main

[2][email address]

 

Privacy notice: By submitting a request for access to documents, the ECB
collects information about you for the sole purpose of processing your
request in accordance with Decision ECB/2004/3 on public access to ECB
documents. All personal data are processed in accordance with EU Data
Protection Law (Regulation (EU) 2018/1725). The ECB is the controller for
the processing of the personal data. The recipients of the data will be
the ECB’s Compliance and Governance Office and, only when necessary, other
institutions within the European System of Central Banks, the Single
Supervisory Mechanism, or EU institutions.

You have the right to restrict processing and to access, rectify and under
certain conditions to request deletion of your stored personal data. You
can exercise your rights by contacting the ECB's Compliance and Governance
Office ([3][email address]) or the ECB’s Data Protection
Officer ([4][email address]).Furthermore, you have the right to address
the European Data Protection Supervisor ([5]www.edps.europa.eu) any time
regarding this processing of your personal data.

 

 

Afficher les sections citées

Dear Access to documents,

We noticed that no answer was provided to the request for the disclosure of separate bond value under CSPP and PEPP within the legal period of 20 working days.

Please indicate if an extension is needed and when an answer can be expected.

Yours sincerely,

Paul Schreiber

Reclaim Finance

Access to documents,

Dear Mr Schreiber,
 
The deadline for the reply to your request received on 22 April 2020 will
elapse on 20 May 2020. We regret to inform you that due to exceptional
workload, we have to invoke Article 8.2 of [1]Decision ECB/2004/3 on
public access to ECB documents and extend the time limit provided to reply
to your request by an additional 20 working days (excluding ECB holidays).
 
Please rest assured that we are giving careful consideration to your
request and will endeavour to reply within the new time limit.
 
Yours sincerely,
 
Compliance and Governance Office
DG Secretariat
European Central Bank
Sonnemannstrasse 20
60314 Frankfurt am Main
[2][email address]
[3][email address]
 

Afficher les sections citées

Dear European Central Bank,

Please pass this on to the person who reviews confirmatory applications.

I am filing the following confirmatory application with regards to my access to documents request 'Disclosure of separate bond value under CSPP and PEPP'.

The European Central Bank already extended the time limite provided to respond to this request and, under all circumstance, should have responded to it by now.

A full history of my request and all correspondence is available on the Internet at this address: https://www.asktheeu.org/en/request/disc...

Yours faithfully,

Paul Schreiber

Access to documents,

Dear Mr Schreiber,

We refer to our message of 18 May 2020, informing you of the extension of the deadline for response to your request for access to European Central Bank (ECB) documents. Please kindly note that the extended deadline will only expire on Monday, 22 June. In this respect, the ECB reply, which is currently being finalised, could reach you shortly after expiry of the deadline.

We sincerely apologise in advance for the inconvenience that any additional delay may cause.

In the event of total or partial refusal of disclosure of the requested documents, you will be entitled to submit a confirmatory application in accordance with Article 7.2 of Decision ECB/2004/3 on public access to ECB documents.

Yours sincerely,

Compliance and Governance Office
DG Secretariat
European Central Bank
Sonnemannstrasse 20
60314 Frankfurt am Main
[email address]
[email address]

________________________________________
From: Paul Schreiber
Sent: Wednesday, 17 June 2020 16:57:25 (UTC+01:00) Amsterdam, Berlin, Bern, Rome, Stockholm, Vienna
To: [email address]
Subject: [EXT] Internal review of access to documents request - Disclosure of separate bond value under CSPP and PEPP

Dear European Central Bank,

Please pass this on to the person who reviews confirmatory applications.

I am filing the following confirmatory application with regards to my access to documents request 'Disclosure of separate bond value under CSPP and PEPP'.

The European Central Bank already extended the time limite provided to respond to this request and, under all circumstance, should have responded to it by now.

A full history of my request and all correspondence is available on the Internet at this address: https://www.asktheeu.org/en/request/disc...

Yours faithfully,

Paul Schreiber

-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #7876 email]

This message and all replies from European Central Bank will be published on the AsktheEU.org website. For more information see our dedicated page for EU public officials at https://www.asktheeu.org/en/help/officers

Please note that in some cases publication of requests and responses will be delayed.

-------------------------------------------------------------------
Any e-mail message from the European Central Bank (ECB) is sent in good faith, but shall neither be binding nor construed as constituting a commitment by the ECB except where provided for in a written agreement. This e-mail is intended only for the use of the recipient(s) named above. Any unauthorised disclosure, use or dissemination, either in whole or in part, is prohibited. If you have received this e-mail in error, please notify the sender immediately via e-mail and delete this e-mail from your system. The ECB processes personal data in line with Regulation (EU) 2018/1725. In case of queries, please contact the ECB Data Protection Officer ([email address]). You may also contact the European Data Protection Supervisor.

Dear European Central Bank,

Please pass this on to the person who reviews confirmatory applications.

I am filing the following confirmatory application with regards to my access to documents request 'Disclosure of separate bond value under CSPP and PEPP'.

As your previous response stated, the European Central Bank should have responded by June 22. However, one week later no answer has been provided.

A full history of my request and all correspondence is available on the Internet at this address: https://www.asktheeu.org/en/request/disc...

Yours faithfully,

Paul Schreiber

Access to documents,

1 Attachment

Dear Mr Schreiber,
Please find attached the ECB's reply to your request of 22 April 2020 for access to European Central Bank (ECB) documents.

Yours sincerely,

Compliance and Governance Office
DG Secretariat
European Central Bank
Sonnemannstrasse 20
60314 Frankfurt am Main
[email address]

Afficher les sections citées

Dear European Central Bank,

Please pass this on to the person who reviews confirmatory applications.

I am filing the following confirmatory application with regards to my access to documents request 'Disclosure of separate bond value under CSPP and PEPP'.

I am dissatisfied with the ECB's refusal (LS/PS/2020/21) to provide access to the requested documents for the following reason.

I/ Basis of the ECB’s refusal to disclose the separate bond value of assets held under CSPP and PEPP

a. Regarding the Second indent of Article 4(1)(a) of Decision ECB/2004/3

The ECB's refusal relies on the Second indent of Article 4(1)(a) of Decision ECB/2004/3.

This Decision was taken at a time where environment was not one of the ECB’s concern. As such, it grants the ECB the possibility to refuse to disclose information when it “would undermine the protection of the public interest” but does not account for the fact that “the protection of the public interest” also entails the disclosure of detailed information on the climate impact of the ECB’s operations.

b. Regarding the effect of the disclosure on volatility and price discovery

The ECB refused the request arguing that "granting market participants access to detailed, disaggregated information regarding the CSPP/PEPP portfolios, could introduce undue volatility and distort price discovery in the market while compromising the effectiveness of the intervention measures and, potentially, their monetary policy objective".

I do not agree with the ECB for the following reasons:
1. The ECB provides no credible evidence or data to justify that the disclosure of separate bond value would “introduce undue volatility” or “distort price discovery”.
2. Market participants already have "detailed and disaggregated" information on the CSPP and PEEP portfolios as the list of corporate bond securities is already published and includes the ISIN of bonds. Yet, the ECB does not consider that this information "introduce undue volatility and distort price discovery".
3. Whether information is published or not, the ECB's asset purchases already impact "price discovery" and asset prices.

Moreover, the ECB indicates “that the disclosure of detailed, disaggregated data on the securities purchased and held under the CSPP/PEPP (such as the separate bond value of CSPP and PEPP assets held by the Eurosystem) in a centralized and complete manner would lead market participants to draw inferences about the Eurosystem holdings and adjust their own behavior according to assumptions established on the basis of the information made available”.

However, the ECB already discloses the list of CSPP/PEPP corporate bonds in a “centralized and complete manner” and it is not clear that the additional disclosure of bond value would lead market participants to significantly modify their behavior. Furthermore, as the ECB explains in its response, the list of corporate bond securities under CSPP/PEPP is published on a weekly basis and not in real time. If the bond values were to be published at the same time, they would give little usable information to market participants.

Finally, when it comes to the climate impact of asset purchases, an alternative to the disclosure of separate bond value would be for the ECB to disclose aggregated information about the climate impact of its bond purchases. Namely, the ECB would need to start by disclosing the information mentioned in the request for access to document : https://www.asktheeu.org/en/request/disc... .

II/ The ECB’s commentary related to the climate impact of its purchases and the disclosure of climate related information

a. Regarding the “neutrality” of asset purchases

The ECB writes that “the implementation of the APP and PEPP are guided by the principle of market neutrality and does not positively or negatively discriminate on the basis of environmental or any other criteria. In the specific case of the CSPP and PEPP, the purchases of securities issued by non-bank corporations reflect proportionally the market value of all eligible bonds in terms of sectors of economic activity and rating groups.”

This is not true, as the ECB’s portfolio is mainly composed of carbon-intensive sectors and is more exposed to fossil fuels and less to low-carbon transports than the rest of the market.

Furthermore, market neutrality negates the political dimension of monetary creation and is totally anachronistic in the context of the climate emergency. Getting on track for the COP21 climate objectives requires institutions to redirect financial flows to support a 1.5°C trajectory. The notion of the transition itself implies both exiting unsustainable sectors and developing sustainable alternatives.

Yet, by trying to reproduce the market, the principle of market neutrality reinforces a polluting and fossil fuel-dependent economy. This principle is out of step with mechanisms that are currently developing to integrate climate risks, with the NGFS, the Task Force On Financial Disclosure (TCFD) at the European level, the Science Based Target Initiative (SBTI) internationally, or Article 173 of the energy transition law (LTECV) in France. Also, by allowing for carbon-intensive assets to accumulate on the ECB’s balance, it exposes the ECB to important and unaccounted financial risks and a breach of its fiduciary duty.

On the other hand, the ECB’s climate intervention is fully justified by European law as it fulfills its complementary mandates. It would contribute to the EU’s objectives, favor the emergence of sustainable growth, and respect the Paris Agreement. By intervening, the ECB would follow the EU’s key objectives and principles: It would protect Europe from future COVID-like disasters and their unprecedented economic and financial consequences.

b. Regarding the lack of “granular and forward-looking analyses of the carbon intensity” and the shortcomings of sectoral data

For the ECB, “meaningful assessment of the environmental impacts of the ECB asset purchases requires granular and forward-looking analyses of the carbon intensity of the investments financed by the bond issuances that benefitted from our asset purchases. This is currently not possible given the existing data gaps.”.

I note that the ECB clearly states that its asset purchases have an environmental impact. But, while building additional knowledge is useful and needed to achieve a complete “greening” of the financial system, concrete and rapid action is crucial and ample information is available to act right now.

As the ECB’s asset purchases reached historical proportions amid the COVID crisis, finance 38 fossil fuel companies – even in coal and shale oil and gas – and could end up supporting polluters to up to 220 billion, we do not have time to wait and the strategic review won’t produce any concrete results before 2022.

In fact, to keep global warming close to 1.5°C, we need progressively phase out fossil fuels to live in a fossil free world by 2050. More precisely, we need to phase out coal as soon as 2030 in Europe and the OECD and 2040 worldwide and oil and gas ten years later. These key objectives should immediately be used to assess the impact of the ECB’s operations and reduce it, thus aligning with European climate objectives. As GHG emissions are concentrated in a few most polluting sectors – including fossil fuels – these objectives would allow the ECB to swiftly improve its carbon footprint.

The ECB would probably respond that “sectoral data do not capture large differences within sectors and, most importantly, ignore any dynamics within firms over time. An example of such shortcomings is that issuance of green bonds is typically concentrated in sectors such as utilities, infrastructure, transportation and construction, which based on backward looking sectoral data, would be considered carbon intensive, despite them financing sustainable projects.”

But this is not a valid argument: the reduction of GHG emissions requires to simultaneously reduce polluting activities and scale up low-carbon alternatives, this depends on the global policy of the company and not on a single project. To ensure that its asset purchases are in line with the ecological transition, the ECB needs to buy bonds from companies that adopt plans to align on a 1.5°C trajectory. For fossil fuels, this means adopting the previously mentioned objectives.

c. Regarding PEPP’s crucial place in the ECB’s response to the Covid-19

The ECB emphasizes that “the successful implementation of the PEPP is critical for an effective monetary policy transmission mechanism aimed at delivering the favourable financial conditions that are necessary to support the economy, in view of the severe risks to the outlook for the euro area posed by the COVID-19 pandemic”.

I would like to stress that the lack of climate criteria in the PEPP is rising climate-related risks and, by refusing to fight against climate change and protect nature, contributing to future Covid-like crisis. As many European leaders and financial players have stated, the response to Covid needs to be “green”. Monetary policy should not be exempted from this green imperative. Ending the support that PEPP provides to the most polluting companies is a logical and necessary step.

A full history of my request and all correspondence is available on the Internet at this address: https://www.asktheeu.org/en/request/disc...

Yours faithfully,

Paul Schreiber
Reclaim Finance

Access to documents,

Dear Mr Schreiber,

 

Thank you for your confirmatory application of 1 July 2020, for access to
European Central Bank (ECB) documents.

In accordance with Decision ECB/2004/3 on public access to ECB documents,
as last amended, you will receive a reply within 20 working days.

 

Yours sincerely

 

Compliance and Governance Office

DG Secretariat

European Central Bank

Sonnemannstrasse 20

60314 Frankfurt am Main

[email address]

 

 

 

________________________________________

From: Paul Schreiber

Sent: Wednesday, 01 July 2020 14:47:49 (UTC+01:00) Amsterdam, Berlin,
Bern, Rome, Stockholm, Vienna

To: [email address]

Subject: [EXT] Internal review of access to documents request - Disclosure
of separate bond value under CSPP and PEPP

 

Dear European Central Bank,

 

Please pass this on to the person who reviews confirmatory applications.

 

I am filing the following confirmatory application with regards to my
access to documents request 'Disclosure of separate bond value under CSPP
and PEPP'.

 

I am dissatisfied with the ECB's refusal (LS/PS/2020/21) to provide access
to the requested documents for the following reason.

 

I/ Basis of the ECB’s refusal to disclose the separate bond value of
assets held under CSPP and PEPP

 

a. Regarding the Second indent of Article 4(1)(a) of Decision ECB/2004/3

 

The ECB's refusal relies on the Second indent of Article 4(1)(a) of
Decision ECB/2004/3.

 

This Decision was taken at a time where environment was not one of the
ECB’s concern. As such, it grants the ECB the possibility to refuse to
disclose information when it “would undermine the protection of the public
interest” but does not account for the fact that “the protection of the
public interest” also entails the disclosure of detailed information on
the climate impact of the ECB’s operations.

 

b. Regarding the effect of the disclosure on volatility and price
discovery

 

The ECB refused the request arguing that "granting market participants
access to detailed, disaggregated information regarding the CSPP/PEPP
portfolios, could introduce undue volatility and distort price discovery
in the market while compromising the effectiveness of the intervention
measures and, potentially, their monetary policy objective".

 

I do not agree with the ECB for the following reasons:

1.      The ECB provides no credible evidence or data to justify that the
disclosure of separate bond value would “introduce undue volatility” or
“distort price discovery”.

2.      Market participants already have "detailed and disaggregated"
information on the CSPP and PEEP portfolios as the list of corporate bond
securities is already published and includes the ISIN of bonds. Yet, the
ECB does not consider that this information "introduce undue volatility
and distort price discovery".

3.      Whether information is published or not, the ECB's asset purchases
already impact "price discovery" and asset prices.

 

Moreover, the ECB indicates “that the disclosure of detailed,
disaggregated data on the securities purchased and held under the
CSPP/PEPP (such as the separate bond value of CSPP and PEPP assets held by
the Eurosystem) in a centralized and complete manner would lead market
participants to draw inferences about the Eurosystem holdings and adjust
their own behavior according to assumptions established on the basis of
the information made available”.

 

However, the ECB already discloses the list of CSPP/PEPP corporate bonds
in a “centralized and complete manner” and it is not clear that the
additional disclosure of bond value would lead market participants to
significantly modify their behavior. Furthermore, as the ECB explains in
its response, the list of corporate bond securities under CSPP/PEPP is
published on a weekly basis and not in real time. If the bond values were
to be published at the same time, they would give little usable
information to market participants.

 

Finally, when it comes to the climate impact of asset purchases, an
alternative to the disclosure of separate bond value would be for the ECB
to disclose aggregated information about the climate impact of its bond
purchases. Namely, the ECB would need to start by disclosing the
information mentioned in the request for access to document :
https://www.asktheeu.org/en/request/disc...
.

 

II/ The ECB’s commentary related to the climate impact of its purchases
and the disclosure of climate related information

 

a. Regarding the “neutrality” of asset purchases

 

The ECB writes that “the implementation of the APP and PEPP are guided by
the principle of market neutrality and does not positively or negatively
discriminate on the basis of environmental or any other criteria. In the
specific case of the CSPP and PEPP, the purchases of securities issued by
non-bank corporations reflect proportionally the market value of all
eligible bonds in terms of sectors of economic activity and rating
groups.”

 

This is not true, as the ECB’s portfolio is mainly composed of
carbon-intensive sectors and is more exposed to fossil fuels and less to
low-carbon transports than the rest of the market.

 

Furthermore, market neutrality negates the political dimension of monetary
creation and is totally anachronistic in the context of the climate
emergency. Getting on track for the COP21 climate objectives requires
institutions to redirect financial flows to support a 1.5°C trajectory.
The notion of the transition itself implies both exiting unsustainable
sectors and developing sustainable alternatives.

 

Yet, by trying to reproduce the market, the principle of market neutrality
reinforces a polluting and fossil fuel-dependent economy. This principle
is out of step with mechanisms that are currently developing to integrate
climate risks, with the NGFS, the Task Force On Financial Disclosure
(TCFD) at the European level, the Science Based Target Initiative (SBTI)
internationally, or Article 173 of the energy transition law (LTECV) in
France. Also, by allowing for carbon-intensive assets to accumulate on the
ECB’s balance, it exposes the ECB to important and unaccounted financial
risks and a breach of its fiduciary duty.

 

On the other hand, the ECB’s climate intervention is fully justified by
European law as it fulfills its complementary mandates. It would
contribute to the EU’s objectives, favor the emergence of sustainable
growth, and respect the Paris Agreement. By intervening, the ECB would
follow the EU’s key objectives and principles: It would protect Europe
from future COVID-like disasters and their unprecedented economic and
financial consequences.

 

b. Regarding the lack of “granular and forward-looking analyses of the
carbon intensity” and the shortcomings of sectoral data

 

For the ECB, “meaningful assessment of the environmental impacts of the
ECB asset purchases requires granular and forward-looking analyses of the
carbon intensity of the investments financed by the bond issuances that
benefitted from our asset purchases. This is currently not possible given
the existing data gaps.”.

 

I note that the ECB clearly states that its asset purchases have an
environmental impact. But, while building additional knowledge is useful
and needed to achieve a complete “greening” of the financial system,
concrete and rapid action is crucial and ample information is available to
act right now.

 

As the ECB’s asset purchases reached historical proportions amid the COVID
crisis, finance 38 fossil fuel companies – even in coal and shale oil and
gas – and could end up supporting polluters to up to 220 billion, we do
not have time to wait and the strategic review won’t produce any concrete
results before 2022.

 

In fact, to keep global warming close to 1.5°C, we need progressively
phase out fossil fuels to live in a fossil free world by 2050. More
precisely, we need to phase out coal as soon as 2030 in Europe and the
OECD and 2040 worldwide and oil and gas ten years later. These key
objectives should immediately be used to assess the impact of the ECB’s
operations and reduce it, thus aligning with European climate objectives.
As GHG emissions are concentrated in a few most polluting sectors –
including fossil fuels – these objectives would allow the ECB to swiftly
improve its carbon footprint.

 

The ECB would probably respond that “sectoral data do not capture large
differences within sectors and, most importantly, ignore any dynamics
within firms over time. An example of such shortcomings is that issuance
of green bonds is typically concentrated in sectors such as utilities,
infrastructure, transportation and construction, which based on backward
looking sectoral data, would be considered carbon intensive, despite them
financing sustainable projects.”

 

But this is not a valid argument: the reduction of GHG emissions requires
to simultaneously reduce polluting activities and scale up low-carbon
alternatives, this depends on the global policy of the company and not on
a single project. To ensure that its asset purchases are in line with the
ecological transition, the ECB needs to buy bonds from companies that
adopt plans to align on a 1.5°C trajectory. For fossil fuels, this means
adopting the previously mentioned objectives.

 

c. Regarding PEPP’s crucial place in the ECB’s response to the Covid-19

 

The ECB emphasizes that “the successful implementation of the PEPP is
critical for an effective monetary policy transmission mechanism aimed at
delivering the favourable financial conditions that are necessary to
support the economy, in view of the severe risks to the outlook for the
euro area posed by the COVID-19 pandemic”.

 

I would like to stress that the lack of climate criteria in the PEPP is
rising climate-related risks and, by refusing to fight against climate
change and protect nature, contributing to future Covid-like crisis. As
many European leaders and financial players have stated, the response to
Covid needs to be “green”. Monetary policy should not be exempted from
this green imperative. Ending the support that PEPP provides to the most
polluting companies is a logical and necessary step.

 

A full history of my request and all correspondence is available on the
Internet at this address:
https://www.asktheeu.org/en/request/disc...

 

Yours faithfully,

 

Paul Schreiber

Reclaim Finance

 

 

 

-------------------------------------------------------------------

Please use this email address for all replies to this request:

[FOI #7876 email]

 

This message and all replies from European Central Bank will be published
on the AsktheEU.org website. For more information see our dedicated page
for EU public officials at https://www.asktheeu.org/en/help/officers

 

Please note that in some cases publication of requests and responses will
be delayed.

 

-------------------------------------------------------------------

Any e-mail message from the European Central Bank (ECB) is sent in good
faith, but shall neither be binding nor construed as constituting a
commitment by the ECB except where provided for in a written agreement.
This e-mail is intended only for the use of the recipient(s) named above.
Any unauthorised disclosure, use or dissemination, either in whole or in
part, is prohibited. If you have received this e-mail in error, please
notify the sender immediately via e-mail and delete this e-mail from your
system. The ECB processes personal data in line with Regulation (EU)
2018/1725. In case of queries, please contact the ECB Data Protection
Officer ([email address]). You may also contact the European Data
Protection Supervisor.

Nous ne savons pas si la réponse la plus récente à cette demande contient l'information ou non – si vous etes Paul Schreiber veuillez vous connecter et laisser nous savoir.