December 13 2013
EBF Response to the EBA Consultations on currencies with constrained availability of Liquid Assets
The EBF welcomes the opportunity to comment on the EBA consultation paper related to: Currencies with an extremely narrow definition of central bank eligibility (EBA/CP/2013/37); Currencies for which the justified demand for liquid assets exceeds the...
MehrDecember 2 2013
Comments by Die Deutsche Kreditwirtschaft (German Banking Industry Committee)1 on the proposal of...
From the viewpoint of the Deutsche Kreditwirtschaft, some of the changes to the EU Payment Services Directive proposed by the European Commission still need considerable improvement.
MehrNovember 9 2013
Comments regarding the European Commission's proposal for a regulation on indices used as benchmarks...
The European Commission's legislative proposal is of great importance because indices play a significant role for a multitude of financial instruments and financial contracts. In view of their key economic importance as credence goods and in the...
MehrNovember 8 2013
Position on the Proposal for a Regulation of the European Parliament and of the Council on...
On 24 July 2013 the European Commission published its proposal for a Regulation of the European Parliament and of the Council on interchange fees for card-based payment transactions, Com (2013) 550 final. With this proposal the European Commission...
MehrOctober 4 2013
Comments On the Consultation Document “Revised Basel III leverage ratio framework and disclosure...
On 26 June 2013, the Basel Committee for Banking Supervision published its Consultation Document entitled “Revised Basel III leverage ratio framework and disclosure requirements“. We appreciate the present opportunity to share our comments.
MehrAugust 29 2013
Comments Draft Guidelines on capital measures for foreign currency lending to unhedged borrowers in...
As part of a company’s credit assessment, in the field of corporate finance, foreign currency risks have to be identified and evaluated in the same way as other material risks. This does not present a new requirement. Instead, it has always been...
MehrAugust 21 2013
Comments on draft Regulatory Technical Standards on criteria to identify categories of staff whose...
The German Banking Industry Committee express their thanks and have pleasure in availing themselves of this opportunity to submit comments, to express their views on the proposal for RTS and to make further suggestions for amendments of the draft.
MehrJuly 17 2013
Opinion of the German Banking Industry Committee: Consultation Paper on Reforming the Structure of...
The German Banking Industry Committee (GBIC), known domestically as Die Deutsche Kreditwirtschaft, supports the European Commission in its endeavour to increase financial market stability. Stable financial markets are of vital interest to the banking...
MehrJuly 8 2013
Comments by the German Banking Industry Committee on ED/2013/3 Financial Instruments: Expected...
The German Banking Industry Committee welcomes the proposed expected credit loss approach submitted by the IASB which fundamentally addresses the widely criticised shortcomings of the incurred loss model. In this regard, we support the IASB’s credit...
MehrJune 28 2013
Comments on the draft revised General Block Exemption Regulation
As part of its initiative to modernise State aid legislation, the European Commission intends to review Commission Regulation (EC) No 800/2008 of 6 August 2008 declaring certain categories of aid compatible with the common market in application of...
MehrApril 10 2013
Comments by the German Banking Industry Committee on the Exposure Draft "Classification and...
With this Exposure Draft, the IASB has picked up on various points of criticism regarding the already finalised IFRS 9 (2009/2010). The key change is the proposed introduction of the FVTOCI category. The IASB has stated that such a category would...
MehrMarch 28 2013
Comments on the EBA discussion paper “On retail deposits subject to higher outflows for the...
On 21 February 2013, the European Banking Authority (EBA) published its discussion paper entitled “On retail deposits subject to higher outflows for the purposes of liquidity reporting under the draft CRR”. The German Banking Industry (GBIC) hereby...
MehrMarch 28 2013
Comments “On defining liquid assets in the LCR under the draft CRR””
The GBIC welcomes the EBA’s plans to provide banks with uniform criteria that are simple to implement for the purposes of assessing liquid assets. The “Expected output of the EBA analysis” (page 9) clarifies that the definition of these assets shall...
MehrMarch 28 2013
Comments “Revisions to the Basel Securitisation Framework”
In December 2012, the Basel Committee for Banking Supervision (BCBS) published a Consultation Paper entitled “Revisions to the Basel Securitisation Framework”. We would like to thank you for the present opportunity to comment on said Consultation...
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