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 ...Mehr
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...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
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...Mehr