November 9 2023
Additional Comments on the proposal for a Directive for the further harmonisation of insolvency law
The German banking industry committee rejects, above all, the introduction of a pre-pack procedure and a simplified liquidation procedure for micro-entities, which is intended in the light of an improvement of the Capital Markets Union. Added the...
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...
MehrJanuary 30 2019
DK comments on EBA’s Consultation Paper on Draft ITS amending Commission Implementing Regulation...
DK comments on the above-mentioned EBA consultation paper. The EBA changes the ITS requirements in both the credit risk and market risk areas. The exercise is relevant for institutions with IRB models or IMA models (market risk models) in Pillar I.
MehrDecember 6 2018
GBIC calls for leaner and more effective rules on non-performing loans
The German Banking Industry Committee sees room for improvement regarding the resolution adopted today by the European Parliament’s Committee on Economic and Monetary Affairs on what is referred to as the prudential provisioning mechanism ...
MehrDecember 3 2018
Agreement reached on the EU Banking Package on the finishing straight
The German Banking Industry Committee welcomes the fact that the negotiations on what is referred to as the “Banking Package” have recently gained significant depth and momentum and that an important agreement on key issues has been reached at...
MehrJune 6 2018
Comments on the Proposal for a Directive of the European Parliament and of the Council on the...
The European Commission published its Proposal for a Directive on credit servicers, credit purchasers and the recovery of collateral ...
MehrApril 12 2018
Comments on the European Commission’s “Exploratory consultation on the finalisation of Basel III”
On March 16th 2018 the European Commission startet it's first "Exploratory consultation" on the finalisation of Basel III. The German Banking Industry Committee (GBIC/DK) is pleased to participate in the Commission’s initiative.
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Comments on the ECB Draft Guidance to banks on non-performing loans
In September 2016, the ECB issued draft guidance for consultation on how banks should deal with non-performing loans (NPLs).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...
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.
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 24 2016
Proportionality in the future market risk capital requirements and the review of the original...
On 26 May 2106, the European Commission published a consultation document on Proportionality in the future market risk capital requirements and the review of the original exposure method.
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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