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...
MehrJune 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.
MehrMay 25 2018
EFRAG Discussion Paper Equity instruments – Impairment and Recycling
EFRAG has published a discussion paper where alternative rules for accounting of equity instruments according to IFRS 9 (FV-OCI) are discussed ...
MehrMay 14 2018
Comments of the German Banking Industry Committee on the European Commission's legislative proposal...
On 12 March 2018, the European Commission published two legislative proposals to remove obstacles to the cross-border distribution of investment funds and asked for feedback.
MehrMarch 9 2018
Comments on ESMA’s Response form for the Consultation Paper on draft RTS under the new Prospectus...
The German Banking Industry Committee (GBIC) comments the Key financial information in the summary on ESMA’s Response form for the Consultation Paper on draft RTS under the new Prospectus Regulation ...
MehrOctober 25 2016
EBA guidelines to expected credit lossess
In July 2016, the EBA (European Banking Authority) issued draft guidelines on credit risk management practices and accounting for expected losses.
MehrSeptember 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...
MehrAugust 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...
MehrAugust 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.
MehrAugust 10 2016
EBA Consultation paper (EBA/CP/2016/06)
The consultation paper mentions, that the EBA has no specific mandate to elaborate Guidelines on the LCR or on liquidity risk in general terms.
MehrJuly 15 2016
Dividend equivalent payments: Request to postpone the implementation date of Section 871(m)
We welcome the release on 1 July 2016 of Notice 2016-42 containing a revised proposed qualified intermediary agreement. Unfortunately, the notice fails to answer most of our open questions concerning the treatment by qualified derivatives dealers of...
MehrJune 24 2016
Public Consultation Draft Addendum to the ECB Guide on Options and Discretions available in Union...
The sentence “In particular, the ECB will consider the factors set out under paragraph 4 of this Chapter” should be dropped from subparagraphs 1 and 2 of Chapter 3.1. Liquidity waiver requirements under Article 8 of the CRR are irrelevant to the...
MehrJune 3 2016
Comments on Consultative Document on Standardised Measurement Approach for Operational Risk (BCBS...
In autumn 2015, the BCBS announced that it would withdraw the AMA for operational risk. It stated that the rationale for dropping the AMA would be explained in the BCBS’s new consultative document. In our view, however, the consultative document does...
MehrApril 10 2013
Comments by the German Banking Industry Committee on the Exposure Draft "Classification and...
With this Exposure Draft, the IASB has picked up on various points of criticism regarding the already finalised IFRS 9 (2009/2010). The key change is the proposed introduction of the FVTOCI category. The IASB has stated that such a category would...
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