February 28 2022
Comments of the German Banking Industry Committee on EU-Listing-Act
The German Banking Industry Committee commented on EU Commission’s consultation on an EU Listing Act on February 11, 2022.Mehr
June 30 2020
Comments on EBA’s Discussion Paper on the future changes to the EU-wide stress test (EBA/DP/2020/01)
The German Banking Industry Committee (GBIC) has issued its comments to the public consultation of the European Banking Authority (EBA) on the discussion paper on the future changes to the EU-wide stress test. In general, GBIC welcome EBA’s overall...Mehr
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...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
June 6 2018
Comments on the Proposal for a Directive of the European Parliament and of the Council on the...
The European Commission published its Proposal for a Directive on credit servicers, credit purchasers and the recovery of collateral ...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
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...Mehr
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.Mehr
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...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
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