January 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.Mehr
November 18 2016
Comment on the Discussion Paper on the trading obligation for derivatives under MiFIR
The German Banking Industry is grateful for the opportunity to comment on ESMA ́s discussion paper on the trading obligation for derivatives under MiFIR.Mehr
September 14 2016
GBIC: Postpone the PRIIPs Regulation – threat of considerable legal uncertainty until all...
The member associations of the German Banking Industry Committee (GBIC) warn of considerable legal uncertainty surrounding the planned introduction of standardised European key information documents for packaged retail and insurance-based investment...Mehr
June 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.Mehr
June 3 2016
Comments on Consultative Document on Standardised Measurement Approach for Operational Risk (BCBS...
In autumn 2015, the BCBS announced that it would withdraw the AMA for operational risk. It stated that the rationale for dropping the AMA would be explained in the BCBS’s new consultative document. In our view, however, the consultative document does...Mehr