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November 25 2015

Comments on Regulation amending Regulation (EU) No 575/2013 on prudential requirements for credit...

The European Commission presented on September 30th 2015 its proposal for the amendment of the CRR (Capital Requirements Regulation/Kapitaladäquanzverordnung), which would be a result from the introduction of a European regulation for...

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November 25 2015

Comments Regulation laying down common rules on securitisation and creating a European framework for...

The European Commission presented on September 30th 2015 its proposal for a European regulation for so-called STS-securitisations (simple, transparent and standardised). The guidelines were developed under the regulation procedure - along with the...

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October 20 2015

Comments On CPMI-IOSCO’s Consultative report on the harmonisation of the Unique Transaction...

The DK comments the CPMI-IOSCO’s consultative report on the harmonisation of the Unique Transaction Identifier. Further informations are to be read in the attached position paper.

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October 8 2015

Comments1 On DG FISMA consultation paper on the possible impact of the CRR and CRD IV on bank...

The European Commission published at the 15th of July 2015 a consultation paper on the possible impact of the CRR and CRD IV on bank financing of the economy. The DK took up position regarding questions and suggestions. Further informations are to be...

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October 8 2015

Comments1 on the EBA consultation paper on RTS on conditions for capital requirements for mortgage...

The DK comments on the EBA consultation paper on RTS on conditions for capital requirements for mortgage exposures (EBA/CP/2015/12). Further informations are to be withdrawn out of the attached document.

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October 2 2015

EBA Discussion Paper and Call for Evidence on SMEs and the SME Supporting Factor

The DK comments EBAs position paper regarding SME supporting factors, that a the permanent retention of the so-called SME-factors are justified. Further informations are to be withdrawn out of the attached position paper.

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September 16 2015

Comments regarding the Presidency compromise text and the Council discussions on the European...

The DK published a position paper regarding the presidency compromise text and the council discussions on the European Commission’s proposal for a regulation on indices used as benchmarks in financial instruments and financial contracts

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September 11 2015

Comments on BCBS Consultation Paper “Interest rate risk in the banking book” (BCBS 319)

The DK comments on BCBS Consultation Paper “Interest rate risk in the banking book” (BCBS 319). Further informations are to be withdrawn out of the attached position paper.

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September 7 2015

Comments on the amendments proposed by the European Parliament - COM/2012/011

Comments on the amendments proposed by the European Parliament (EP) and the Council regarding the proposal of the European Commission for an EU General Data Protection Regulation (COM/2012/011 final)

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September 2 2015

Comments On the Commission’s Public Consultation on Regulation (EU) No 648/2012 on OTC Derivatives,...

The DK comments On the Commission’s Public Consultation on Regulation (EU) No 648/2012 on OTC Derivatives, Central Counterparties and Trade Repositories. Further informations are to be withdrawn out of the attached comments.

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July 14 2015

Comments On ESAs’ Second Consultation Paper on the Draft Regulatory Technical Standards on...

At the 10th of June 2015 the european supervisory authority established a consultation procedure for collateralisation of its derivate businesses. The attached document contains DK's comments regarding this issues.

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June 23 2015

Dk comments regarding EBA's consultation DK-Stellungnahme zur EBA-Konsultation "Guidelines on limits...

Comments Draft EBA Guidelines on limits on exposures to shadow banking entities which carry out banking activities outside a regulated framework. Further informations are to be withdrawn out of the attached comment paper.

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May 14 2015

Comments on the European Commission's Green Paper on “Building a Capital Markets Union”

The European Commission published at the 18th February 2015 its green paper "Building a Capital Markets Union. The DK principally welcomes the EU-commissions plans on creating a Capital Market Union (CMU) but wants to emphazise that additional...

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May 13 2015

Comments on the EU Framework for Simple, Transparent and Standardised Securitisations

On February 18, 2015 the Consultation Paper for a European regulatory framework for simple, transparent and standardized securitization was published as part of the Green Paper of the European Commission for the "creation of a capital market Union...

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April 30 2015

Comments on the Consultative Document "Guidance on accounting for expected credit losses" (BCBS 311)

The "Deutsche Kreditwirtschaft" commented on the consultative document "Guidance on accounting for expected credit losses" (BCBS 311), which is a draft based on eleven principals regarding BCBS' expectations of Expected-Credit-Loss-Models. Further...

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April 17 2015

Comments on BCBS Consultation Paper "Capital floors: the design of a framework based on standardised...

The "Deutsche Kreditwirtschaft" published a position paper regarding standard approaches for accounting capital requirements. Further informations are to be withdrawn out of the attached position papers.

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March 23 2015

Comments on the "Discussion Paper The Use of Credit Ratings by Financial Intermediaries Article 5(a)...

The European Supervisory Authorithies – ESA’s ( ESMA, EBA and EIOPA) published a discussion paper regarding the usage of external ratings. In the attached comments you will find informations about the evaluation of the usage of external ratings.

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March 13 2015

Comments on the EBA consultation paper "On assessment methodology for IRB approach" (EBA/CP/2014/36)

The "Deutsche Kreditwirtschaft" commented on the EBA consultation paper "On assessment methodology for IRB approach" (EBA/CP/2014/36) regarding technical operation standards. For further informations are to be withdrawn out of the attached position...

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