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 14 2018
Comments on the Draft Commission Implementing Regulation laying down minimum requirements...
Comments of the German Banking Industry Committee on the Draft Commission Implementing Regulation laying down minimum requirements implementing the provisions of Directive 2007/36/EC of the European Parliament and the Council as regards shareholders...Mehr
April 12 2018
Comments on the European Commission’s “Exploratory consultation on the finalisation of Basel III”
On March 16th 2018 the European Commission startet it's first "Exploratory consultation" on the finalisation of Basel III. The German Banking Industry Committee (GBIC/DK) is pleased to participate in the Commission’s initiative.Mehr
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).Mehr
October 26 2016
Comments on the EBA guidelines to identify groups of connected clients
In July 2016, the European Banking Authority (EBA) issued draft guidelines for consultation on the treatment of connected clients under the large exposures regime. The objective is to revise the CEBS guidelines, which were published in 2011, in the...Mehr
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...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
August 17 2016
Comments on ECB Draft AnaCredit Manual
AnaCredit is a project to set up a dataset containing detailed information on individual bank loans in the euro area, harmonised across all Member States. The data collection is scheduled to start in September 2018. In view of the large number of...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
Proportionality in the future market risk capital requirements and the review of the original...
On 26 May 2106, the European Commission published a consultation document on Proportionality in the future market risk capital requirements and the review of the original exposure method.Mehr