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August 30 2023

Position paper and comments of the German Banking Industry Committee on the European Commission’s...

The European Commission presented a proposal for a retail investment strategy (RIS) which, among other things, provides for an amendment of the European Markets in Financial Instruments Directive (MiFID). The German Banking Industry Committee (GBIC)...

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March 13 2019

Comments on Revisions to leverage ratio disclosure requirements

The Basel Committee’s additional leverage ratio disclosure requirements are designed to reflect its concerns about “window-dressing”. The Basel Committee would like to see averaged values disclosed on the basis of values calculated daily. In the view...

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June 21 2018

DK on the planned amendment of MiFID II

The German Banking Industry Committee (DK) commented on the planned amendment of MiFID II ...

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June 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 ...

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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 on the Draft Commission Implementing Regulation laying down minimum requirements...

Comments of the German Banking Industry Committee on the Draft Commission Implementing Regulation laying down minimum requirements implementing the provisions of Directive 2007/36/EC of the European Parliament and the Council as regards shareholders...

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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 20 2018

GBIC comments on ESMA’s consultation on disclosure requirements under the STS-Regulation

The European Securities and Markets Authority (ESMA) consulted draft technical standards on disclosure requirements and operational standards under the Securitisation Regulation. Please find the comments of the German Banking Industry Committee on...

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January 31 2017

Revision of EBA guidelines on internal governance

The European Banking Authority (EBA) published a consultation paper aimed at revising its guidelines on internal governance dating from 2011. The draft guidelines address, inter alia, the interplay of supervisory and management body, roles and...

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November 25 2016

Comments on ECB Draft AnaCredit Manual Part II

ECB published the Draft AnaCredit Reporting Manual Part II Datasets and Data Attributes.

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November 15 2016

Comments on the ECB Draft Guidance to banks on non-performing loans

In September 2016, the ECB issued draft guidance for consultation on how banks should deal with non-performing loans (NPLs). German Banking Industry Committee (GBIC) basically welcomes both the ECB’s plan to harmonise practices concerning the...

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September 27 2016

Comments on Guidelines on disclosure requirements under Part Eight of Regulation (EU) 575/2013...

It is our understanding that the draft guidelines are not intended as implementation in the EU of the first stage of the Basel Pillar 3 Review (BCBS 309). Instead, their purpose is merely to enable EU banks to reconcile existing CRR requirements with...

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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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July 22 2016

EBA RTS on the disclosure of encumered and unencumbered assets (EBA/CP/2016/05)

The European Banking Authority (EBA) consulted the draft of a regulatory standard to disclosure of loaded and unloaded financial assets. Textual the draft is about the development of the already current guideline.

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July 4 2016

BCBS Consultative Document

In the area of supervisory reporting, there are already requirements in form of the EBA ITS on supervisory reporting on forbearance and non-performing exposures implemented at European level by Commission Implementing Regulation (EU) 680/2014, in...

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June 8 2016

Pillar 3 disclosure requirements – consolidated and enhanced framework (BCBS 356)

We welcome the Basel Committee’s intention to review its disclosure requirements with the aim of enhancing the benefit of Pillar 3 reports to users. We also agree that it would make good sense to formalise and standardise the presentation of certain...

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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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