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August 23 2020

Comments on Technical Amendment on capital treatment of securitisations of non-performing loans

The German Banking Industry Committee (GBIC) has issued its comments to the public consultation of the Basel Committee on Banking Supervision (BCBS) on the technical amandment on capital treatment of securisations of non-performing loans (NPL). In...

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January 30 2019

DK comments on EBA’s Consultation Paper on Draft ITS amending Commission Implementing Regulation...

DK comments on the above-mentioned EBA consultation paper. The EBA changes the ITS requirements in both the credit risk and market risk areas. The exercise is relevant for institutions with IRB models or IMA models (market risk models) in Pillar I.

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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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May 25 2018

Comments on the BCBS Pillar 3 disclosure requirements – updated framework

The Basel Committee on Banking Supervision (BCBS) issued on 27 February 2018 a consultative document on the updated Pillar 3 disclosure requirements framework ...

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Comments on the ECB Draft Guidance to banks on non-performing loans

In September 2016, the ECB issued draft guidance for consultation on how banks should deal with non-performing loans (NPLs).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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June 24 2016

Comments on the Basel Committee on Banking Supervision Consultative Document on Reducing variation...

On 24 March 2016, the Basel Committee on Banking Supervision (BCBS) published a consultative document on constraints on the use of internal model approaches.

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October 4 2013

Comments On the Consultation Document “Revised Basel III leverage ratio framework and disclosure...

On 26 June 2013, the Basel Committee for Banking Supervision published its Consultation Document entitled “Revised Basel III leverage ratio framework and disclosure requirements“. We appreciate the present opportunity to share our comments.

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