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June 20 2018

Comments on Minimum Capital Requirements for Market Risk

On March 22, 2018, the Basel Committee on Banking Supervision issued the “Revisions to the minimum capital requirements for market risk” for consultation ...

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May 25 2018

EFRAG Discussion Paper Equity instruments – Impairment and Recycling

EFRAG has published a discussion paper where alternative rules for accounting of equity instruments according to IFRS 9 (FV-OCI) are discussed ...

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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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January 31 2017

Revision of EBA guidelines on internal governance

The European Banking Authority (EBA) published a consultation paper aimed at revising its guidelines on internal governance dating from 2011. The draft guidelines address, inter alia, the interplay of supervisory and management body, roles and...

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November 29 2016

OTC - derivatives

Comments of the German Banking Industry Committee (GBIC) on the consultative Report Harmonisation of critical OTC derivatives data elements (other than UTI and UPI) – second batch.

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November 25 2016

Comments on ECB Draft AnaCredit Manual Part II

ECB published the Draft AnaCredit Reporting Manual Part II Datasets and Data Attributes.

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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.

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November 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Comments on the ECB Draft Guidance to banks on non-performing loans

In September 2016, the ECB issued draft guidance for consultation on how banks should deal with non-performing loans (NPLs).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...

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September 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...

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August 31 2016

Position on the implementation of the NSFR in the EU

By end of 2016 the EU commission has to deliver a proposal in which form to implement the Net Stable Funding Ratio (NSFR) in the EU. The German Banking Industry Committee (GBIC) is pleased to present its priorities relating to this endeavour covering...

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July 22 2016

EBA RTS on the disclosure of encumered and unencumbered assets (EBA/CP/2016/05)

The European Banking Authority (EBA) consulted the draft of a regulatory standard to disclosure of loaded and unloaded financial assets. Textual the draft is about the development of the already current guideline.

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July 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...

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June 8 2016

Pillar 3 disclosure requirements – consolidated and enhanced framework (BCBS 356)

We welcome the Basel Committee’s intention to review its disclosure requirements with the aim of enhancing the benefit of Pillar 3 reports to users. We also agree that it would make good sense to formalise and standardise the presentation of certain...

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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...

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April 19 2016

Guidelines on implicit support under Article 248(2) of Regulation (EU) No 575/2013 (EBA/CP/2016/1)

The EBA provides a guideline for the explanation of the normal market conditions and when a business is structured so that there is no credit support.

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