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November 27 2023

Comments regarding the European Commission's consultation exercise "rationalisation of reporting...

The German Banking Industry Committee (GBIC) welcomes the European Commission’s goal of a 25 percent reduction in the burden on companies and administrative organizations resulting from reporting requirements.

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November 9 2023

Additional Comments on the proposal for a Directive for the further harmonisation of insolvency law

The German banking industry committee rejects, above all, the introduction of a pre-pack procedure and a simplified liquidation procedure for micro-entities, which is intended in the light of an improvement of the Capital Markets Union. Added the...

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October 27 2023

Comments on EBA’s Draft Guidelines on the establishment and maintenance of national lists or...

The European Banking Authority (EBA) launched a public consultation in July 2023 on its Draft Guidelines on the establishment and maintenance of national lists or registers of credit servicers under Directive 2021/2167.

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October 26 2023

Comments on the European Commission's legislative proposals of 28 June 2023 to revise the Second...

The European Commission has presented its proposals on the draft legislation for the revision of the second EU Payment Services Directive (PSD2) on 28 June 2023. The German Banking Industry (DK) welcomes the fact that essential provisions of the...

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October 13 2023

GBIC comments on EBA’s draft templates and template guidance for collecting climate related data...

The European Banking Authority (EBA) launched a public consultation in July 2023 on draft templates and template guidance for collecting climate related data from EU banks.

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October 11 2023

GBIC comments on ECB’s Guide on effective risk data aggregation and risk reporting

The European Central Bank (ECB) launched a public consultation in July 2023 on its Guide on effective risk data aggregation and risk reporting.

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October 10 2023

Comments on FSB consultation: Evaluation on Effects of G20 Reforms on Securitisation

The consultation by the Financial Stability Board (FSB) “on the effects of G20 financial regulatory reforms on securitisation” is the start of a global discussion on the review of the securitisation framework.

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October 9 2023

Comments on the EU Commission’s draft Framework for Financial Data Access (FIDA)

The German Banking Industry Committee (GBIC) supports in principle a "Framework for Financial Data Access" that exploits the opportunities of the data economy for European consumers, businesses and the EU economy as a whole.

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October 5 2023

Comments of the German Banking Industry Committee on the BCBS-Consultative Document "Core principles...

The German Banking Industry Committee (Die Deutsche Kreditwirtschaft) welcomes the fact that the Basel Committee on Banking Supervision is revising its principles for effective banking supervision.

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September 26 2023

DK Comments on Post-implementation Review IFRS 9 Financial Instruments Impairment

The German Banking Industry Committee welcomes the “Post-implementation Review IFRS 9 Financial Instruments Impairment” and notes that the implementation of the impairment rules of IFRS 9 has been a very high effort for the banks. In many banks, IFRS...

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September 25 2023

DK Comments on the Commission proposal for a Regulation on ESG rating activities

The Regulation, as proposed, is a step in the right direction in regulating the ESG ratings market and improve the quality of ESG ratings. However, some uncertainties and issues remain, especially with regards to the Regulation’s scope and in the...

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September 19 2023

GBIC comments on ECB’s revised Guide to internal models

The ECB launched a public consultation in June 2023 on its revised Guide to internal models. The revision reflects updates on the legal framework and builds on the ECB’s experience gained over the years in supervising internal models.

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September 14 2023

Position on the current trilogue negotiations on the Artificial Intelligence Act

In general, the German Banking Industry Committee (GBIC) supports the objectives of the AI Act to promote the potential of artificial intelligence for European consumers, companies, and the EU economy as a whole.

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September 13 2023

Comments on Amendments to the Classification and Measurement of Financial Instruments

GBIC welcomes the IASB's approach to address the concerns expressed by stakeholders in the context of the Post-Implementation Review (PIR). Particularly with regard to the ESG issue, we consider it very important that IFRS 9 remains principles based...

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September 8 2023

DK-comments to ESAs Joint Committee consultation on Technical Standards under DORA

The European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) launched a public consultation on the first batch of policy products under the Digital Operational Resilience Act (DORA) in Juni 2023. This is to amend the DORA delegated acts on...

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August 30 2023

Position paper and comments of the German Banking Industry Committee on the European Commission’s...

The European Commission presented a proposal for a retail investment strategy (RIS) which, among other things, provides for an amendment of the European Markets in Financial Instruments Directive (MiFID). The German Banking Industry Committee (GBIC)...

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August 30 2023

Comments Review of the PRIIPs Regulation in the context of Retail Investment Strategy Proposal of...

On 24 May 2023, the European Commission published a draft for the amendment of the PRIIPs Regulation (PRIIPs Draft) within the framework of its Retail Investment Strategy (RIS). The German Banking Industry Committee (GBIC) welcomes the intention of...

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August 14 2023

First Comments on the EU Commission's Legislative Proposal on a digital Euro

On June 28th 2023, the European Commission published its legislative proposal for a digital Euro. While more technical aspects have been discussed so far, fundamental questions must now be answered.

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