August 14 2023
First Comments on the EU Commission's Legislative Proposal on a digital Euro
On June 28th 2023, the European Commission published its legislative proposal for a digital Euro. While more technical aspects have been discussed so far, fundamental questions must now be answered.
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 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 ...
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Comments on the ECB Draft Guidance to banks on non-performing loans
In September 2016, the ECB issued draft guidance for consultation on how banks should deal with non-performing loans (NPLs).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 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...
MehrJuly 22 2016
EBA RTS on the disclosure of encumered and unencumbered assets (EBA/CP/2016/05)
The European Banking Authority (EBA) consulted the draft of a regulatory standard to disclosure of loaded and unloaded financial assets. Textual the draft is about the development of the already current guideline.
MehrJuly 4 2016
BCBS Consultative Document
In the area of supervisory reporting, there are already requirements in form of the EBA ITS on supervisory reporting on forbearance and non-performing exposures implemented at European level by Commission Implementing Regulation (EU) 680/2014, in...
MehrJune 8 2016
Pillar 3 disclosure requirements – consolidated and enhanced framework (BCBS 356)
We welcome the Basel Committee’s intention to review its disclosure requirements with the aim of enhancing the benefit of Pillar 3 reports to users. We also agree that it would make good sense to formalise and standardise the presentation of certain...
MehrJune 3 2016
Comments on Consultative Document on Standardised Measurement Approach for Operational Risk (BCBS...
In autumn 2015, the BCBS announced that it would withdraw the AMA for operational risk. It stated that the rationale for dropping the AMA would be explained in the BCBS’s new consultative document. In our view, however, the consultative document does...
MehrApril 19 2016
Guidelines on implicit support under Article 248(2) of Regulation (EU) No 575/2013 (EBA/CP/2016/1)
The EBA provides a guideline for the explanation of the normal market conditions and when a business is structured so that there is no credit support.
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