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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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November 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.

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June 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 ...

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May 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 ...

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May 4 2018

Comments on ECB’s Guide to the internal liquidity adequacy assessment process (ILAAP)

The German Banking Industry Committee (GBIC) has commented on the ECB’s Public consultation on the draft ECB Guide to the internal liquidity adequacy assessment processes (ILAAP) ...

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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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October 26 2016

Comments on the EBA guidelines to identify groups of connected clients

In July 2016, the European Banking Authority (EBA) issued draft guidelines for consultation on the treatment of connected clients under the large exposures regime. The objective is to revise the CEBS guidelines, which were published in 2011, in the...

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October 24 2016

Comments to the consultation of the European Commission on the review of the EU macro-prudential...

The German Banking Industry Committee (GBIC) took part in the consultation of the European Commission on the review of the EU macro-Prudential policy framework. The consultation took place to gather feedback and evidence on whether the existing EU...

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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 17 2016

Comments on ECB Draft AnaCredit Manual

AnaCredit is a project to set up a dataset containing detailed information on individual bank loans in the euro area, harmonised across all Member States. The data collection is scheduled to start in September 2018. In view of the large number of...

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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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July 29 2016

Comments on the EBA Discussion Paper on innovative uses

The Deutsche Kreditwirtschaft participates on consultation of the European Banking Authority (EBA) for innovative usability of consumer data.

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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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