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)...Mehr
November 18 2016
Comment on the Discussion Paper on the trading obligation for derivatives under MiFIR
The German Banking Industry is grateful for the opportunity to comment on ESMA ́s discussion paper on the trading obligation for derivatives under MiFIR.Mehr
November 15 2016
Comments on the ECB Draft Guidance to banks on non-performing loans
In September 2016, the ECB issued draft guidance for consultation on how banks should deal with non-performing loans (NPLs). German Banking Industry Committee (GBIC) basically welcomes both the ECB’s plan to harmonise practices concerning the...Mehr
October 26 2016
Comments on the EBA guidelines to identify groups of connected clients
In July 2016, the European Banking Authority (EBA) issued draft guidelines for consultation on the treatment of connected clients under the large exposures regime. The objective is to revise the CEBS guidelines, which were published in 2011, in the...Mehr
October 24 2016
Comments to the consultation of the European Commission on the review of the EU macro-prudential...
The German Banking Industry Committee (GBIC) took part in the consultation of the European Commission on the review of the EU macro-Prudential policy framework. The consultation took place to gather feedback and evidence on whether the existing EU...Mehr
October 12 2016
GBIC’s response to the EBA Consultation Paper “EBA-CP-2016-11"
The German Banking Industry Committee (GBIC) welcomes the EBA consultation paper and the opportunity offered to provide feedback on the future draft Regulatory Technical Standards (RTS) on strong customer authentication (SCA) and secure communication...Mehr
September 27 2016
Comments on Guidelines on disclosure requirements under Part Eight of Regulation (EU) 575/2013...
It is our understanding that the draft guidelines are not intended as implementation in the EU of the first stage of the Basel Pillar 3 Review (BCBS 309). Instead, their purpose is merely to enable EU banks to reconcile existing CRR requirements with...Mehr
September 20 2016
Comments on BCBS and IOSCO Consultative Document Criteria for identifying simple, transparent and...
We welcome the initiative of the Basel Committee on Banking Supervision and the International Organisation of Securities Commissions to define criteria for identifying simple, transparent and comparable securitisations. In particular, we consider...Mehr
September 20 2016
Comments on the EBA Consultation Paper “Draft Guidelines on methods for calculating contributions to...
The "Deutsche Kreditwirtschaft" commented EBA's published consultation papers from 11/10/2014 about methods of calculation of deposit insurance systems.Mehr
September 6 2016
Position paper on adjustment of the European large exposure rules in the CRD/CRR review
The large exposure rules are currently being revised at European level. Firstly, the large exposures framework published by the Basel Committee on Banking Supervision in April 2014 is to be implemented and, secondly, the European Commission is...Mehr
September 1 2016
Comments on the European Commission proposal for a directive amending the Fourth Anti-Money...
The German Banking Industry Committee (GBIC) would like to take the reopened debate on creation of an optimal anti-money laundering and counter-terrorist financing (AML/CFT) framework as an opportunity to input its own experience and ideas.Mehr
August 31 2016
Position on the implementation of the NSFR in the EU
By end of 2016 the EU commission has to deliver a proposal in which form to implement the Net Stable Funding Ratio (NSFR) in the EU. The German Banking Industry Committee (GBIC) is pleased to present its priorities relating to this endeavour covering...Mehr
August 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.Mehr