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October 11 2023

GBIC comments on ECB’s Guide on effective risk data aggregation and risk reporting

The European Central Bank (ECB) launched a public consultation in July 2023 on its Guide on effective risk data aggregation and risk reporting.

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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 7 2018

GBIC-Comments on the ECB guide to internal models - risk-type-specific chapters

The German Banking Industry Committee (GBIC) has commented on the draft ECB guide to internal models – Risk-type-specific chapters issued for public consultation on 7 September 2018.

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May 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 ...

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May 28 2018

Comments on the draft ECB guide to internal models – General topics chapter

The German Banking Industry Committee (GBIC) has commented on the draft ECB guide to internal models – General topics chapter as part of the ECB's public consultation ...

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May 4 2018

Comments on ECB’s Guide to the internal liquidity adequacy assessment process (ILAAP)

The German Banking Industry Committee (GBIC) has commented on the ECB’s Public consultation on the draft ECB Guide to the internal liquidity adequacy assessment processes (ILAAP) ...

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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 24 2016

Comments to the consultation of the European Commission on the review of the EU macro-prudential...

The German Banking Industry Committee (GBIC) took part in the consultation of the European Commission on the review of the EU macro-Prudential policy framework. The consultation took place to gather feedback and evidence on whether the existing EU...

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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 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...

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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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August 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.

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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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June 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...

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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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