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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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August 4 2021

GBIC comments on a retail investment strategy for Europe

The German Banking Industry Committee has commented on the EU draft of a "Retail Investment Strategy" and, among other things, has spoken out against a possible ban on inducements.

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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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December 21 2018

Comments on Commission proposal on a DELEGATED REGULATION supplementing Regulation (EU) 2017/1129

Comments on Commission proposal on a DELEGATED REGULATION supplementing Regulation (EU) 2017/1129 as regards the format, content, scrutiny and approval of the prospectus and repealing Commission Regulation (EC) No 809/2004 ...

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November 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...

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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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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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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...

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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...

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August 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.

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June 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...

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July 17 2013

Opinion of the German Banking Industry Committee: Consultation Paper on Reforming the Structure of...

The German Banking Industry Committee (GBIC), known domestically as Die Deutsche Kreditwirtschaft, supports the European Commission in its endeavour to increase financial market stability. Stable financial markets are of vital interest to the banking...

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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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