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.
MehrFebruary 28 2022
Comments of the German Banking Industry Committee on EU-Listing-Act
The German Banking Industry Committee commented on EU Commission’s consultation on an EU Listing Act on February 11, 2022.
MehrNovember 28 2018
Comments on Draft Implementing Standards amending Implementing Regulation with regard to FINREP
We generally welcome the principle of proportionality in the additional reporting obligations for non-performing exposures (NPEs) which is reflected by the separation according to Module 1 and 2. That being said, we believe that it is possible to...
MehrNovember 7 2018
GBIC-Comments on the ECB guide to internal models - risk-type-specific chapters
The German Banking Industry Committee (GBIC) has commented on the draft ECB guide to internal models – Risk-type-specific chapters issued for public consultation on 7 September 2018.
MehrMay 28 2018
Comments on the draft ECB guide to internal models – General topics chapter
The German Banking Industry Committee (GBIC) has commented on the draft ECB guide to internal models – General topics chapter as part of the ECB's public consultation ...
MehrMay 4 2018
Comments on ECB’s Guide to the internal liquidity adequacy assessment process (ILAAP)
The German Banking Industry Committee (GBIC) has commented on the ECB’s Public consultation on the draft ECB Guide to the internal liquidity adequacy assessment processes (ILAAP) ...
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 ...
MehrNovember 25 2016
Comments on ECB Draft AnaCredit Manual Part II
ECB published the Draft AnaCredit Reporting Manual Part II Datasets and Data Attributes.
MehrOctober 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...
MehrOctober 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...
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 17 2016
Comments on ECB Draft AnaCredit Manual
AnaCredit is a project to set up a dataset containing detailed information on individual bank loans in the euro area, harmonised across all Member States. The data collection is scheduled to start in September 2018. In view of the large number 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...
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