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...
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...
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 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 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 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
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...
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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