August 30 2023
Position paper and comments of the German Banking Industry Committee on the European Commission’s...
The European Commission presented a proposal for a retail investment strategy (RIS) which, among other things, provides for an amendment of the European Markets in Financial Instruments Directive (MiFID). The German Banking Industry Committee (GBIC)...
MehrMay 23 2019
Italian-German Dialogue on Financial Services: a 10-point agenda from FeBAF and DK
The 10-point agenda was discussed today during the 4th round of the Italian-German Dialogue on Financial Services between the Italian Banking Insurance and Finance Federation (FeBAF, to whom 13 financial associations in Italy adhere) and the DK (...
MehrMarch 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...
MehrNovember 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...
MehrJune 21 2018
DK on the planned amendment of MiFID II
The German Banking Industry Committee (DK) commented on the planned amendment of MiFID II ...
MehrJune 20 2018
Comments on Minimum Capital Requirements for Market Risk
On March 22, 2018, the Basel Committee on Banking Supervision issued the “Revisions to the minimum capital requirements for market risk” for consultation ...
MehrMay 25 2018
EFRAG Discussion Paper Equity instruments – Impairment and Recycling
EFRAG has published a discussion paper where alternative rules for accounting of equity instruments according to IFRS 9 (FV-OCI) are discussed ...
MehrMay 14 2018
Comments on the Draft Commission Implementing Regulation laying down minimum requirements...
Comments of the German Banking Industry Committee on the Draft Commission Implementing Regulation laying down minimum requirements implementing the provisions of Directive 2007/36/EC of the European Parliament and the Council as regards shareholders...
MehrMay 14 2018
Comments of the German Banking Industry Committee on the European Commission's legislative proposal...
On 12 March 2018, the European Commission published two legislative proposals to remove obstacles to the cross-border distribution of investment funds and asked for feedback.
MehrMarch 20 2018
GBIC comments on ESMA’s consultation on disclosure requirements under the STS-Regulation
The European Securities and Markets Authority (ESMA) consulted draft technical standards on disclosure requirements and operational standards under the Securitisation Regulation. Please find the comments of the German Banking Industry Committee on...
MehrJanuary 31 2017
Revision of EBA guidelines on internal governance
The European Banking Authority (EBA) published a consultation paper aimed at revising its guidelines on internal governance dating from 2011. The draft guidelines address, inter alia, the interplay of supervisory and management body, roles and...
MehrNovember 25 2016
Comments on ECB Draft AnaCredit Manual Part II
ECB published the Draft AnaCredit Reporting Manual Part II Datasets and Data Attributes.
MehrNovember 15 2016
Comments on the ECB Draft Guidance to banks on non-performing loans
In September 2016, the ECB issued draft guidance for consultation on how banks should deal with non-performing loans (NPLs). German Banking Industry Committee (GBIC) basically welcomes both the ECB’s plan to harmonise practices concerning the...
MehrOctober 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...
MehrSeptember 27 2016
Comments on Guidelines on disclosure requirements under Part Eight of Regulation (EU) 575/2013...
It is our understanding that the draft guidelines are not intended as implementation in the EU of the first stage of the Basel Pillar 3 Review (BCBS 309). Instead, their purpose is merely to enable EU banks to reconcile existing CRR requirements with...
MehrSeptember 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...
MehrAugust 31 2016
Position on the implementation of the NSFR in the EU
By end of 2016 the EU commission has to deliver a proposal in which form to implement the Net Stable Funding Ratio (NSFR) in the EU. The German Banking Industry Committee (GBIC) is pleased to present its priorities relating to this endeavour covering...
MehrAugust 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...
Mehr