November 29 2016
Response to EBA Draft Guidelines on third-party provider insurance
The German Banking Industry Committee responded to EBA Consultation Paper on the Draft Guidelines on the criteria on how to stipulate the minimum monetary amount of the professional indemnity insurance or other comparable guarantee under Article 5(4)...
MehrSeptember 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...
MehrAugust 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.
MehrJuly 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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