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November 3 2020

Comments EBA GL Fit & Proper

The German Banking Industry Committee (GBIC) has issued its comments to the public consultation of the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) - EBA/GL/2020/19 - on the revision of joint guidelines...

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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 9 2018

Comments on ESMA’s Response form for the Consultation Paper on draft RTS under the new Prospectus...

The German Banking Industry Committee (GBIC) comments the Key financial information in the summary on ESMA’s Response form for the Consultation Paper on draft RTS under the new Prospectus Regulation ...

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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 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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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Comments on the ECB Draft Guidance to banks on non-performing loans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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August 31 2016

Comments on Notice 2016-42 (proposed changes to qualified intermediary agreements)

The new rules in section 5.03(B) of the proposed QI agreement provide that the LOB declaration (which may be used by entities that are not fiscally transparent to document their status together with “alternative” documentary evidence.

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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 15 2016

Dividend equivalent payments: Request to postpone the implementation date of Section 871(m)

We welcome the release on 1 July 2016 of Notice 2016-42 containing a revised proposed qualified intermediary agreement. Unfortunately, the notice fails to answer most of our open questions concerning the treatment by qualified derivatives dealers of...

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