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...
MehrNovember 25 2016
Comments on ECB Draft AnaCredit Manual Part II
ECB published the Draft AnaCredit Reporting Manual Part II Datasets and Data Attributes.
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 8 2013
Comments by the German Banking Industry Committee on ED/2013/3 Financial Instruments: Expected...
The German Banking Industry Committee welcomes the proposed expected credit loss approach submitted by the IASB which fundamentally addresses the widely criticised shortcomings of the incurred loss model. In this regard, we support the IASB’s credit...
MehrApril 10 2013
Comments by the German Banking Industry Committee on the Exposure Draft "Classification and...
With this Exposure Draft, the IASB has picked up on various points of criticism regarding the already finalised IFRS 9 (2009/2010). The key change is the proposed introduction of the FVTOCI category. The IASB has stated that such a category would...
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