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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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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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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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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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September 27 2016

Comments on Guidelines on disclosure requirements under Part Eight of Regulation (EU) 575/2013...

It is our understanding that the draft guidelines are not intended as implementation in the EU of the first stage of the Basel Pillar 3 Review (BCBS 309). Instead, their purpose is merely to enable EU banks to reconcile existing CRR requirements with...

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September 6 2016

Position paper on adjustment of the European large exposure rules in the CRD/CRR review

The large exposure rules are currently being revised at European level. Firstly, the large exposures framework published by the Basel Committee on Banking Supervision in April 2014 is to be implemented and, secondly, the European Commission is...

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August 31 2016

Position on the implementation of the NSFR in the EU

By end of 2016 the EU commission has to deliver a proposal in which form to implement the Net Stable Funding Ratio (NSFR) in the EU. The German Banking Industry Committee (GBIC) is pleased to present its priorities relating to this endeavour covering...

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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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July 4 2016

BCBS Consultative Document

In the area of supervisory reporting, there are already requirements in form of the EBA ITS on supervisory reporting on forbearance and non-performing exposures implemented at European level by Commission Implementing Regulation (EU) 680/2014, in...

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June 24 2016

Public Consultation Draft Addendum to the ECB Guide on Options and Discretions available in Union...

The sentence “In particular, the ECB will consider the factors set out under paragraph 4 of this Chapter” should be dropped from subparagraphs 1 and 2 of Chapter 3.1. Liquidity waiver requirements under Article 8 of the CRR are irrelevant to the...

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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...

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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...

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