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
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
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
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
October 12 2016
GBIC’s response to the EBA Consultation Paper “EBA-CP-2016-11"
The German Banking Industry Committee (GBIC) welcomes the EBA consultation paper and the opportunity offered to provide feedback on the future draft Regulatory Technical Standards (RTS) on strong customer authentication (SCA) and secure communication...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 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
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
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...Mehr
December 2 2013
Comments by Die Deutsche Kreditwirtschaft (German Banking Industry Committee)1 on the proposal of...
From the viewpoint of the Deutsche Kreditwirtschaft, some of the changes to the EU Payment Services Directive proposed by the European Commission still need considerable improvement.Mehr