September 8 2023
DK-comments to ESAs Joint Committee consultation on Technical Standards under DORA
The European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) launched a public consultation on the first batch of policy products under the Digital Operational Resilience Act (DORA) in Juni 2023. This is to amend the DORA delegated acts on...
MehrAugust 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)...
MehrNovember 3 2020
Comments EBA GL Fit & Proper
The German Banking Industry Committee (GBIC) has issued its comments to the public consultation of the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) - EBA/GL/2020/19 - on the revision of joint guidelines...
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...
MehrMay 28 2018
EU Banking Package: EU Council adopts general approach
One of the aims of the general approach adopted by the EU Council today to what is referred to as the “Banking Package” (CRR II / CRD V) is to tighten the own funds requirements ...
MehrMarch 9 2018
Comments on ESMA’s Response form for the Consultation Paper on draft RTS under the new Prospectus...
The German Banking Industry Committee (GBIC) comments the Key financial information in the summary on ESMA’s Response form for the Consultation Paper on draft RTS under the new Prospectus Regulation ...
MehrJanuary 6 2017
Comments on the ESMA Consultation Paper - Draft guidelines on MiFID II product governance...
The German Banking Industry Committee (GBIC) has submitted comments on "ESMA Consultation Paper - Draft guidelines on MiFID II product governance requirements" (ESMA/2016/1436).
MehrDecember 2 2016
EU regulatory framework for benchmarks
The European Securities and Markets Authority ESMA consulted on technical standards under the Benchmarks Regulation. The German Banking Industry Committee contributed to the process and sent its comments to ESMA.
MehrNovember 29 2016
SFT-Regulation
Comments of the German Banking Industry Committee (GBIC) on ESMA’s discussion paper – Draft RTS and IST under SFTR.
MehrNovember 18 2016
Comment on the Discussion Paper on the trading obligation for derivatives under MiFIR
The German Banking Industry is grateful for the opportunity to comment on ESMA ́s discussion paper on the trading obligation for derivatives under MiFIR.
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 10 2016
EBA Consultation paper (EBA/CP/2016/06)
The consultation paper mentions, that the EBA has no specific mandate to elaborate Guidelines on the LCR or on liquidity risk in general terms.
MehrJuly 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.
MehrJuly 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.
MehrJune 24 2016
Public Consultation Draft Addendum to the ECB Guide on Options and Discretions available in Union...
The sentence “In particular, the ECB will consider the factors set out under paragraph 4 of this Chapter” should be dropped from subparagraphs 1 and 2 of Chapter 3.1. Liquidity waiver requirements under Article 8 of the CRR are irrelevant to the...
MehrFebruary 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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