August 23 2020
Comments on Technical Amendment on capital treatment of securitisations of non-performing loans
The German Banking Industry Committee (GBIC) has issued its comments to the public consultation of the Basel Committee on Banking Supervision (BCBS) on the technical amandment on capital treatment of securisations of non-performing loans (NPL). In...
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 25 2018
Comments on the BCBS Pillar 3 disclosure requirements – updated framework
The Basel Committee on Banking Supervision (BCBS) issued on 27 February 2018 a consultative document on the updated Pillar 3 disclosure requirements framework ...
MehrAugust 31 2016
Comments on Notice 2016-42 (proposed changes to qualified intermediary agreements)
The new rules in section 5.03(B) of the proposed QI agreement provide that the LOB declaration (which may be used by entities that are not fiscally transparent to document their status together with “alternative” documentary evidence.
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 15 2016
Dividend equivalent payments: Request to postpone the implementation date of Section 871(m)
We welcome the release on 1 July 2016 of Notice 2016-42 containing a revised proposed qualified intermediary agreement. Unfortunately, the notice fails to answer most of our open questions concerning the treatment by qualified derivatives dealers of...
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.
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...
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.
Mehr
