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October 1 2021

DK Response to ESMA Consultation on the Draft of the new EMIR Reporting Guidelines

DK participated in the consultation on ESMA guidelines for EMIR reporting requirements. EMIR Refit aims to align the reporting standards with international standards and to harmonize with SFTR reporting. The aim is to increase the data quality of the...

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September 30 2021

GBIC comments on EBA consultation paper on revised RTS on credit risk adjustments (EBA/CP/2021/25)

The GBIC advocates that newly created risk provisions should avoid a double burden on Common Equity Tier 1 capital.

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September 28 2021

GBIC comments on the current EBA consultation on draft SREP guidelines and supervisory stress...

GBIC welcomes the decision to update the SREP Guidelines. We also agree with the overarching objectives, namely (a) to increase convergence of practices followed by competent authorities across the EU, and (b) to align the SREP Guidelines with other...

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September 28 2021

GBIC welcomes proposal for an EU standard for green bonds – further revisions necessary

The German Banking Industry Committee welcomes the European Commission's proposal for an EU standard for green bonds. As part of the European Green Deal, it is of the utmost importance that the EU standard for green bonds is established in a...

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September 24 2021

DK comments on EBA consultation paper on COREP and asset encumbrance reporting (EBA/CP/2021/24)

We welcome that, regardless of a threshold calculation, small and non-complex institutions (SNCIs) will be exempt from extended reporting requirements. However, in the light of the underlying objective to reduce supervisory costs using...

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September 14 2021

GBIC comments on the regulatory treatment of cryptoassets

The GBIC has commented on a consultation of the Basel Committee on Banking Supervision on the regulatory treatment of crypto assets. From the point of view of the DK, a uniform global framework is required for the regulatory handling of crypto...

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September 14 2021

Targeted consultation of the European Commission: GBIC rejects the introduction of an EU-wide data...

From the GBIC's point of view, there is already a high level of transparency on the secondary markets for non-performing loans (NPLs). The market participants know each other, their standards and particular expertise. If NPL are not sold, price...

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September 2 2021

GBIC comments on EBA draft ITS on IRRBB disclosure (EBA/CP/2021/20)

GBIC understands EBA’s wish to implement the strengthening of supervisory convergence in Europe for interest rate risk exposures in the banking book (IRRBB) through its disclosure standards and the new IRRBB requirements, which are still expected....

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September 2 2021

GBIC comments on the EBA discussion paper on the review of the NPL transaction data templates...

GBIC expressly supports the revision of the NPL transaction data templates with the aim of a simpler, more proportionate and more effective design in order to achieve a broader application and increase transparency in the NPL market. However, even...

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August 4 2021

GBIC comments on a retail investment strategy for Europe

The German Banking Industry Committee has commented on the EU draft of a "Retail Investment Strategy" and, among other things, has spoken out against a possible ban on inducements.

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June 14 2021

GBIC-response to the EU Commission's consultation on the statutory replacement of the three-month...

On 5 March 2021, the Financial Conduct Authority (FCA) announced the discontinuation of CHF, GBP, JPY, EUR and certain USD LIBOR benchmarks at the end of 2021. The EU Commission then initiated a consultation procedure and is now examining whether the...

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June 8 2021

GBIC comments on the European Commission's consultation on supervisory convergence and the single...

In spring 2021, the European Commission launched a public consultation on the ESAs, which marks the start of the current ESA review. The regular ESA reviews provide an opportunity to assess and to improve on the regulatory framework as well as the...

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June 7 2021

GBIC comments on the requirements of Article 8 of the TaxonomyRegulation

The requirements of the Delegated Act are very extensive and appear to be too complex and impracticable, including in light of the level of detail. We welcome the transitional periods provided for by the European Commission, but see further scope for...

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June 2 2021

GBIC comments on EBA's Draft Implementing Standards on prudential disclosures on ESG risks in...

In its current version, the level of detail of the information required for the green asset ratio is very high. Moreover,  GBIC considers the duplicate disclosure of templates in two external reports by the institutions to be superfluous (templates 8...

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May 10 2021

GBIC comments on the Targeted consultation on the review of the Directive on settlement finality in...

The Commission reviews how Member States apply the Settlement Finality Directive to their domestic institutions which participate directly in systems governed by the law of a third country and to collateral security provided in connection with...

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April 28 2021

Guidelines on certain aspects of the MiFID II appropriateness and execution-only requirements

At the End of January 2021 the European Securities and Markets Authority (ESMA) published draft Guidelines on certain aspects of the MiFID II appropriateness and execution-only requirements and opened a consultation process. GBIC has commented on the...

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March 30 2021

GBIC comments on the consultation on the 2021 ex-ante SRF contributions calculation

According to the German Banking Industry Committee (GBIC), the calculation procedure for the ex-ante contributions to the Single Resolution Fund still lacks transparency.

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March 5 2021

IOSCO Consultation on Market Data in the secondary Equity Markets

The International Organization of Securities Commissions  (IOSCO) has consulted the market regarding the importance and challenges of market data. GBIC has underpinned the importance of market data in its opinion. Market data must be available at a...

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