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August 4 2021

GBIC comments on a retail investment strategy for Europe

The German Banking Industry Committee has commented on the EU draft of a "Retail Investment Strategy" and, among other things, has spoken out against a possible ban on inducements.

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October 30 2019

Comments on EBA Draft guidelines on the determination of the weighted average maturity (WAM) of...

Guidelines on the determination of the weighted average maturity (WAM) of contractual payments due under the tranche.

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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 ...

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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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March 20 2018

GBIC comments on the homogeneity of underlying exposures in securitisations

EBA has consulted a regulatory technical standard (RTS) on the homogeneity of underlying exposures in securitisations, based on its mandate in the recently published STS-regulation. In order to benefit from less harsh capital requirements,...

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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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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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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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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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April 19 2016

Guidelines on implicit support under Article 248(2) of Regulation (EU) No 575/2013 (EBA/CP/2016/1)

The EBA provides a guideline for the explanation of the normal market conditions and when a business is structured so that there is no credit support.

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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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