August 8 2019
GBIC Comments on Consultative Document: Consolidated Basel Framework (BCBS 462)
DK comments on the Basel Consultation Paper on the Consolidated Framework.
MoreJuly 3 2019
EFRAG consultation on Equity Instruments – Research on Measurement
EFRAG has published a questionnaire to explore alternative accounting treatments for long-term equity instruments under IFRS. The German Banking Industry Committee does no see a need at present to discuss this topic resp. for changes to IFRS 9. It...
MoreJune 17 2019
IASB Exposure Draft ED/2019/1 Bechmark Reform
IASB proposes changes to IAS 39 and IFRS 9 due to possible effects of the IBOR reform. GBIC basically agrees with the proposals but advocates also for reliefs concerning retrospective effectiveness testing and dynamic hedging according to IAS 39.
MoreMay 24 2019
Comments on the draft EBA Guidelines on Credit Risk Mitigation within the A-IRB
The German Banking Industry Committee (GBIC) has commented on the draft EBA Guidelines on Credit Risk Mitigation for institutions applying the IRB Approach with own estimates of LGDs.
MoreMarch 13 2019
Comments on Revisions to leverage ratio disclosure requirements
The Basel Committee’s additional leverage ratio disclosure requirements are designed to reflect its concerns about “window-dressing”. The Basel Committee would like to see averaged values disclosed on the basis of values calculated daily. In the view...
MoreJanuary 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.
MoreDecember 21 2018
Comments on Commission proposal on a DELEGATED REGULATION supplementing Regulation (EU) 2017/1129
Comments on Commission proposal on a DELEGATED REGULATION supplementing Regulation (EU) 2017/1129 as regards the format, content, scrutiny and approval of the prospectus and repealing Commission Regulation (EC) No 809/2004 ...
MoreNovember 28 2018
Comments on Draft Implementing Standards amending Implementing Regulation with regard to FINREP
We generally welcome the principle of proportionality in the additional reporting obligations for non-performing exposures (NPEs) which is reflected by the separation according to Module 1 and 2. That being said, we believe that it is possible to...
MoreNovember 7 2018
GBIC-Comments on the ECB guide to internal models - risk-type-specific chapters
The German Banking Industry Committee (GBIC) has commented on the draft ECB guide to internal models – Risk-type-specific chapters issued for public consultation on 7 September 2018.
MoreNovember 5 2018
Position Paper on the Proposal of the European Commission for a Directive on representative actions
Accompanying the draft report of the committee on Legal Affairs of the European Parliament (JURI) of 12 October 2018 the German Banking Industry Committee (GBIC) outlines core requirements on the introduction of European representative actions. In...
MoreSeptember 25 2018
Comments on Draft EBA Guidelines on Outsourcing
On 22 June 2018, the EBA published a consultation paper on its Guidelines on Outsourcing arrangements (EBA/CP/2018/11). The German Banking Industry Committee (GBIC) appreciates the opportunity to comment. The GBIC believes that the obligations for...
MoreAugust 30 2018
Comments on the European Commission’s Proposal for a Regulation on sovereign bond-backed securities
The European Commission (COM) published a proposal for a “Regulation of the European Parliament and of the Council on sovereign bond-backed securities” for consultation on 24 May 2018. We appreciate the opportunity to submit our comments.
MoreAugust 24 2018
Comments on the proposal for a regulation on the establishment of a framework to facilitate...
The German Banking Industry Committee (GBIC) supports the European Commission’s initiative to raise more funding for a sustainable economy in Europe and to promote financial market stability. To achieve these objectives, it is essential to establish...
MoreAugust 10 2018
Comments on the EBA Draft Guidelines on specification of types of exposures to be associated with...
The European Banking Authority (EBA) issued its Draft Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of Regulation (EU) No 575/2013 for consultation on 17 April 2018. We appreciate the...
MoreAugust 10 2018
Comments on the EBA Draft Guidelines on disclosure of non-performing and forborne exposures
The European Banking Authority (EBA) published its Draft Guidelines on disclosure of non-performing and forborne exposures for consultation on 27 April 2018. We appreciate the opportunity to submit our comments.
MoreJuly 31 2018
Comments on EBA guidelines on STS criteria (securitisation)
The German Banking Industry Committee (GBIC) has commented EBA’s consultation on guidelines on STS-criteria for ABCP and non-ABCP securitisations. GBIC advocates for clear STS criteria, in order to be able to easily and legally certain assess,...
MoreJuly 30 2018
Comments on the Proposal of the European Commission for a Directive on representative actions to...
In the opinion of the German Banking Industry Committee (GBIC), there is no need for a European initiative to introduce representative actions to protect the collective interests of consumers.
MoreJune 22 2018
Comments on EBA RTS and Guidelines on estimation and identification of an economic downturn
The German Banking Industry Committee has commented on the EBA's Draft Regulatory Technical Standards on the specification of the nature, severity and duration of an economic down-turn and on the EBA Guidelines for the estimation of LGD appropriate...
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