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December 3 2018

Agreement reached on the EU Banking Package on the finishing straight

The German Banking Industry Committee welcomes the fact that the negotiations on what is referred to as the “Banking Package” have recently gained significant depth and momentum and that an important agreement on key issues has been reached at...

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Comments

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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Comments

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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Comments

August 31 2016

Comments on Notice 2016-42 (proposed changes to qualified intermediary agreements)

The new rules in section 5.03(B) of the proposed QI agreement provide that the LOB declaration (which may be used by entities that are not fiscally transparent to document their status together with “alternative” documentary evidence.

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Comments

July 15 2016

Dividend equivalent payments: Request to postpone the implementation date of Section 871(m)

We welcome the release on 1 July 2016 of Notice 2016-42 containing a revised proposed qualified intermediary agreement. Unfortunately, the notice fails to answer most of our open questions concerning the treatment by qualified derivatives dealers of...

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