January 8 2021
Comments on the FSB’s Discussion paper on Regulatory and Supervisory Issues Relating to Outsourcing...
The FSB is taking up an increasingly important topic for the financial industry, addressing not only the risks involved, but also the advantages that can be associated with outsourcing for institutions.Mehr
January 30 2019
DK comments on EBA’s Consultation Paper on Draft ITS amending Commission Implementing Regulation...
DK comments on the above-mentioned EBA consultation paper. The EBA changes the ITS requirements in both the credit risk and market risk areas. The exercise is relevant for institutions with IRB models or IMA models (market risk models) in Pillar I.Mehr
June 22 2018
Comments on EBA RTS and Guidelines on estimation and identification of an economic downturn
The German Banking Industry Committee has commented on the EBA's Draft Regulatory Technical Standards on the specification of the nature, severity and duration of an economic down-turn and on the EBA Guidelines for the estimation of LGD appropriate...Mehr
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 ...Mehr
June 24 2016
Proportionality in the future market risk capital requirements and the review of the original...
On 26 May 2106, the European Commission published a consultation document on Proportionality in the future market risk capital requirements and the review of the original exposure method.Mehr
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...Mehr