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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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June 20 2018

Comments on Minimum Capital Requirements for Market Risk

On March 22, 2018, the Basel Committee on Banking Supervision issued the “Revisions to the minimum capital requirements for market risk” for 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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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 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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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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