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November 9 2023

Additional Comments on the proposal for a Directive for the further harmonisation of insolvency law

The German banking industry committee rejects, above all, the introduction of a pre-pack procedure and a simplified liquidation procedure for micro-entities, which is intended in the light of an improvement of the Capital Markets Union. Added the...

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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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February 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.

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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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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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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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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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January 6 2017

Comments on the ESMA Consultation Paper - Draft guidelines on MiFID II product governance...

The German Banking Industry Committee (GBIC) has submitted comments on "ESMA Consultation Paper - Draft guidelines on MiFID II product governance requirements" (ESMA/2016/1436).

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December 2 2016

EU regulatory framework for benchmarks

The European Securities and Markets Authority ESMA consulted on technical standards under the Benchmarks Regulation. The German Banking Industry Committee contributed to the process and sent its comments to ESMA.

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November 29 2016

SFT-Regulation

Comments of the German Banking Industry Committee (GBIC) on ESMA’s discussion paper – Draft RTS and IST under SFTR.

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November 29 2016

OTC - derivatives

Comments of the German Banking Industry Committee (GBIC) on the consultative Report Harmonisation of critical OTC derivatives data elements (other than UTI and UPI) – second batch.

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November 18 2016

Comment on the Discussion Paper on the trading obligation for derivatives under MiFIR

The German Banking Industry is grateful for the opportunity to comment on ESMA ́s discussion paper on the trading obligation for derivatives under MiFIR.

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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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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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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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