May 23 2019
Italian-German Dialogue on Financial Services: a 10-point agenda from FeBAF and DK
The 10-point agenda was discussed today during the 4th round of the Italian-German Dialogue on Financial Services between the Italian Banking Insurance and Finance Federation (FeBAF, to whom 13 financial associations in Italy adhere) and the DK (...
MehrMay 25 2018
Comments on the European Commission’s proposal for a Regulation of the European Parliament and the...
The European Commission (COM) published a proposal for a Regulation on amending Regulation (EU) No 575/2013 as regards minimum loss coverage for non-performing exposures on 14 March 2018 ...
MehrMarch 9 2018
Comments on ESMA’s Response form for the Consultation Paper on draft RTS under the new Prospectus...
The German Banking Industry Committee (GBIC) comments the Key financial information in the summary on ESMA’s Response form for the Consultation Paper on draft RTS under the new Prospectus Regulation ...
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...
MehrJune 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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