October 11 2023
GBIC comments on ECB’s Guide on effective risk data aggregation and risk reporting
The European Central Bank (ECB) launched a public consultation in July 2023 on its Guide on effective risk data aggregation and risk reporting.
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...
MehrNovember 7 2018
GBIC-Comments on the ECB guide to internal models - risk-type-specific chapters
The German Banking Industry Committee (GBIC) has commented on the draft ECB guide to internal models – Risk-type-specific chapters issued for public consultation on 7 September 2018.
MehrMay 28 2018
Comments on the draft ECB guide to internal models – General topics chapter
The German Banking Industry Committee (GBIC) has commented on the draft ECB guide to internal models – General topics chapter as part of the ECB's public consultation ...
MehrMay 4 2018
Comments on ECB’s Guide to the internal liquidity adequacy assessment process (ILAAP)
The German Banking Industry Committee (GBIC) has commented on the ECB’s Public consultation on the draft ECB Guide to the internal liquidity adequacy assessment processes (ILAAP) ...
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 24 2016
Comments to the consultation of the European Commission on the review of the EU macro-prudential...
The German Banking Industry Committee (GBIC) took part in the consultation of the European Commission on the review of the EU macro-Prudential policy framework. The consultation took place to gather feedback and evidence on whether the existing EU...
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.
MehrJune 24 2016
Public Consultation Draft Addendum to the ECB Guide on Options and Discretions available in Union...
The sentence “In particular, the ECB will consider the factors set out under paragraph 4 of this Chapter” should be dropped from subparagraphs 1 and 2 of Chapter 3.1. Liquidity waiver requirements under Article 8 of the CRR are irrelevant to the...
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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