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November 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...

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Comments

March 20 2018

GBIC comments on the homogeneity of underlying exposures in securitisations

EBA has consulted a regulatory technical standard (RTS) on the homogeneity of underlying exposures in securitisations, based on its mandate in the recently published STS-regulation. In order to benefit from less harsh capital requirements,...

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Comments

March 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...

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