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...Mehr
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.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
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 ...Mehr
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 ...Mehr
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Comments on the ECB Draft Guidance to banks on non-performing loans
In September 2016, the ECB issued draft guidance for consultation on how banks should deal with non-performing loans (NPLs).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...Mehr
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.Mehr
July 29 2016
Comments on the EBA Discussion Paper on innovative uses
The Deutsche Kreditwirtschaft participates on consultation of the European Banking Authority (EBA) for innovative usability of consumer data.Mehr
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...Mehr
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.Mehr
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.Mehr
July 8 2013
Comments by the German Banking Industry Committee on ED/2013/3 Financial Instruments: Expected...
The German Banking Industry Committee welcomes the proposed expected credit loss approach submitted by the IASB which fundamentally addresses the widely criticised shortcomings of the incurred loss model. In this regard, we support the IASB’s credit...Mehr
April 10 2013
Comments by the German Banking Industry Committee on the Exposure Draft "Classification and...
With this Exposure Draft, the IASB has picked up on various points of criticism regarding the already finalised IFRS 9 (2009/2010). The key change is the proposed introduction of the FVTOCI category. The IASB has stated that such a category would...Mehr