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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...

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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)...

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November 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...

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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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March 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 ...

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January 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).

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December 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.

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November 29 2016

SFT-Regulation

Comments of the German Banking Industry Committee (GBIC) on ESMA’s discussion paper – Draft RTS and IST under SFTR.

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November 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.

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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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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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