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 ...
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.
MehrNovember 5 2018
Position Paper on the Proposal of the European Commission for a Directive on representative actions
Accompanying the draft report of the committee on Legal Affairs of the European Parliament (JURI) of 12 October 2018 the German Banking Industry Committee (GBIC) outlines core requirements on the introduction of European representative actions. In...
MehrSeptember 25 2018
Comments on Draft EBA Guidelines on Outsourcing
On 22 June 2018, the EBA published a consultation paper on its Guidelines on Outsourcing arrangements (EBA/CP/2018/11). The German Banking Industry Committee (GBIC) appreciates the opportunity to comment. The GBIC believes that the obligations for...
MehrAugust 30 2018
Comments on the European Commission’s Proposal for a Regulation on sovereign bond-backed securities
The European Commission (COM) published a proposal for a “Regulation of the European Parliament and of the Council on sovereign bond-backed securities” for consultation on 24 May 2018. We appreciate the opportunity to submit our comments.
MehrAugust 24 2018
Comments on the proposal for a regulation on the establishment of a framework to facilitate...
The German Banking Industry Committee (GBIC) supports the European Commission’s initiative to raise more funding for a sustainable economy in Europe and to promote financial market stability. To achieve these objectives, it is essential to establish...
MehrAugust 10 2018
Comments on the EBA Draft Guidelines on specification of types of exposures to be associated with...
The European Banking Authority (EBA) issued its Draft Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of Regulation (EU) No 575/2013 for consultation on 17 April 2018. We appreciate the...
MehrAugust 10 2018
Comments on the EBA Draft Guidelines on disclosure of non-performing and forborne exposures
The European Banking Authority (EBA) published its “Draft Guidelines on disclosure of non-performing and forborne exposures” for consultation on 27 April 2018. We appreciate the opportunity to submit our comments.
MehrJuly 31 2018
Comments on EBA guidelines on STS criteria (securitisation)
The German Banking Industry Committee (GBIC) has commented EBA’s consultation on guidelines on STS-criteria for ABCP and non-ABCP securitisations. GBIC advocates for clear STS criteria, in order to be able to easily and legally certain assess,...
MehrJuly 30 2018
Comments on the Proposal of the European Commission for a Directive on representative actions to...
In the opinion of the German Banking Industry Committee (GBIC), there is no need for a European initiative to introduce representative actions to protect the collective interests of consumers.
MehrJune 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...
MehrJune 21 2018
DK on the planned amendment of MiFID II
The German Banking Industry Committee (DK) commented on the planned amendment of MiFID II ...
MehrJune 20 2018
Comments on Minimum Capital Requirements for Market Risk
On March 22, 2018, the Basel Committee on Banking Supervision issued the “Revisions to the minimum capital requirements for market risk” for consultation ...
MehrJune 8 2018
Comments on the EBA Draft Guidelines on management of non-performing and forborne exposures
The German Banking Industry Committee (GBIC) has commented on the“Draft Guidelines on management of non-performing and forborne exposures” published for consultation by the European Banking Authority (EBA) on 8 March 2018 ...
MehrJune 6 2018
Comments on the Proposal for a Directive of the European Parliament and of the Council on the...
The European Commission published its Proposal for a Directive on credit servicers, credit purchasers and the recovery of collateral ...
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 25 2018
Comments on the BCBS Pillar 3 disclosure requirements – updated framework
The Basel Committee on Banking Supervision (BCBS) issued on 27 February 2018 a consultative document on the updated Pillar 3 disclosure requirements framework ...
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