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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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June 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.

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May 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 ...

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May 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.

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March 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 ...

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October 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.

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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.

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July 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...

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June 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...

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April 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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