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August 14 2023

First Comments on the EU Commission's Legislative Proposal on a digital Euro

On June 28th 2023, the European Commission published its legislative proposal for a digital Euro. While more technical aspects have been discussed so far, fundamental questions must now be answered.

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March 13 2019

Comments on Revisions to leverage ratio disclosure requirements

The Basel Committee’s additional leverage ratio disclosure requirements are designed to reflect its concerns about “window-dressing”. The Basel Committee would like to see averaged values disclosed on the basis of values calculated daily. In the view...

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November 28 2018

Comments on Draft Implementing Standards amending Implementing Regulation with regard to FINREP

We generally welcome the principle of proportionality in the additional reporting obligations for non-performing exposures (NPEs) which is reflected by the separation according to Module 1 and 2. That being said, we believe that it is possible to...

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November 25 2016

Comments on ECB Draft AnaCredit Manual Part II

ECB published the Draft AnaCredit Reporting Manual Part II Datasets and Data Attributes.

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October 26 2016

Comments on the EBA guidelines to identify groups of connected clients

In July 2016, the European Banking Authority (EBA) issued draft guidelines for consultation on the treatment of connected clients under the large exposures regime. The objective is to revise the CEBS guidelines, which were published in 2011, in the...

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September 6 2016

Position paper on adjustment of the European large exposure rules in the CRD/CRR review

The large exposure rules are currently being revised at European level. Firstly, the large exposures framework published by the Basel Committee on Banking Supervision in April 2014 is to be implemented and, secondly, the European Commission is...

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August 17 2016

Comments on ECB Draft AnaCredit Manual

AnaCredit is a project to set up a dataset containing detailed information on individual bank loans in the euro area, harmonised across all Member States. The data collection is scheduled to start in September 2018. In view of the large number of...

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July 22 2016

German Banking Industry Committee and Austrian Economic Chambers: Position paper on the...

The position paper by GBIC and WKO looks at individual aspects of the leverage ratio whose analysis is required under Article 511 of the CRR.

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July 7 2016

Comments on the Basel Committee on Banking Supervision’s consultative document on revisions to the...

The Deutsche Kreditwirtschaft give its opinion to Basels consultation documents for the definition of the Leverage Ratio. This definition is reworked on several places.

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Press-Releases

February 25 2016

New GBIC expert opinion: leverage ratio sets serious perverse incentives

A leverage ratio will not make the financial system more stable. On the contrary, an inflexible instrument of this kind sets dangerous perverse incentives. This is the conclusion of a new expert opinion commissioned by the member associations of the...

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