2. Comments

Comments on the European Commission’s “Exploratory consultation on the finalisation of Basel III”

12 April 2018
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 ... ]

EBA Discussion Paper on SA-CCR and FRTB

21 March 2018
The European Banking Authority (EBA) had published in December 2017 a discussion paper on the implementation of the new Standardized Approach for Counterparty Credit Risk (SA-CCR) and the new framework in the area of market risk (FRTB). [ mehr ... ]

GBIC comments on ESMA’s consultation on disclosure requirements under the STS-Regulation

20 March 2018
The European Securities and Markets Authority (ESMA) consulted draft technical standards on disclosure requirements and operational standards under the Securitisation Regulation. Please find the comments of the German Banking Industry Committee on the consultation paper attached. [ mehr ... ]

„Banking business in Europe – how consistent are regulation and supervision really?”

15 March 2018
The supervision of banks in the euro area underwent a fundamental transformation at the end of 2014. With the establishment of the Single Supervisory Mechanism (SSM), which – integrated into the European Central Bank – is responsible for supervising all banks in ... [ mehr ... ]

GBIC comments on the homogeneity of underlying exposures in securitisations

15 March 2018
EBA has consulted a regulatory technical standard (RTS) on the homogeneity of underlying exposures in securitisations, based on its mandate in the recently published STS-regulation. [ mehr ... ]

GBIC comments on EBA draft RTS on the methods of prudential consolidation

9 February 2018
Please find attached the comments of GBIC on EBA draft RTS on the methods of prudential consolidation under Article 18 CRR. GBIC especially points out, that the scope of prudential consolidation should not be extended. [ mehr ... ]

GBIC comments on ESMA Draft RTS on the European Single Electronic Format (ESEF)

5 February 2018
The European Securities and Markets Authority (ESMA) publishes the final draft RTS setting out the new European Single Electronic Format to prepare annual financial reports. [ mehr ... ]

Comments on revised EBA Guidelines on the management of IRRBB

31 January 2018
The German Banking Industry Committee (GBIC) appreciates the opportunity to comment on the Draft Guidelines on the management of interest rate risk arising from non-trading book activities published on 31 October 2017 (EBA/CP/2017/19). [ mehr ... ]

Comments on revised EBA Guidelines on SREP

31 January 2018
On 31 October 2017, the EBA published a consultation paper on the revision of its Guidelines on supervisory review and evaluation process (SREP) and supervisory stress testing (EBA/CP/2017/18). [ mehr ... ]

Comments on EBA’s Draft Guidelines on institution’s stress testing

31 January 2018
The German Banking Industry Committee (GBIC) appreciates the opportunity to comment on the Draft Guidelines on institution’s stress testing published on 31 October 2017 (EBA/CP/2017/17). [ mehr ... ]

Comments on ITS on Supervisory Benchmarking framework for 2019

18 January 2018
The German Banking Industry Committee is the joint committee operated by the central associations of the German banking industry. [ mehr ... ]

Comments on the first ECB public consultation on developing a euro unsecured overnight interest rate

17 January 2018
The German Banking Industry Committee (GBIC/DK) is pleased to participate in the first public consultation on developing a euro unsecured overnight interest rate. [ mehr ... ]

Comments on the proposal of the European Commission for a review of the ESAs’ framework

20 December 2017
The German Banking Industry Committee takes note of the review and reform of the European supervisory system comprising EBA, ESMA and EIOPA. A competitive financial market is of elementary importance for the EU. [ mehr ... ]

GBIC comments on significant risk transfer (securitisations)

19 December 2017
After finalising the new securitisation regulation, EBA has launched a consultation on significant risk transfer. The consultation deals basically with different methods to detect whether there is a significant risk transfer. [ mehr ... ]

Addendum to the ECB Guidance to banks on nonperforming loans

8 December 2017
The ECB has published an addendum to its guidance on nonperforming loans in October which describes the quantiative expectations of the ECB concerning new NPLs. [ mehr ... ]

GBIC response to the proposal for a Regulation of CCPs and third-country CCPs

7 December 2017
The German Banking Industry Committee (GBIC) published a position paper on the proposal for a regulation amending the regulations (EU) No 1095/2010 and (EU) No 648/2012 as regards the procedures and authorities involved for the authorisation of CCPs ... [ mehr ... ]

Comments on the EBA Consultation Paper on the Draft Implementing Standards on the provision of information for the purpose of resolution plans

5 December 2017
The German Banking Industry Committee (GBIC) commented on the EBA Consultation Paper on the Draft Implementing Standards on the provision of information for the purpose of resolution plans. [ mehr ... ]

Consultation of EU Commission concerning „prudential backstops“

30 November 2017
The EU Commission has published its ideas concerning the implementation of “prudential backstops”. [ mehr ... ]

GBIC response to the public consultation on post-trade in a Capital Market Union

15 November 2017
The German Banking Industry Committee (GBIC) published a response to the public consultation on post-trade in a Capital Market Union: dismantling barriers and strategy for the future. [ mehr ... ]

Response to the Discussion Paper on the EBA’s approach to financial technology (FinTech)

1 November 2017
The German Banking Industry Committee (GBIC) commented the proposals put forward in the discussion paper on the EBA’s approach to financial technology and answered the specific questions the EBA detailed in the paper. [ mehr ... ]

Comments on the European Commission consultation on “Transparency and Fees in Cross-Border Transactions in the EU”

30 October 2017
The European Commission conducted a consultation on transparency and fees in cross-border transactions in the EU. The Association of German Banks has completed the questionnaire. [ mehr ... ]

Response to the Basel Committee on Banking Supervision's consultative document on the implications of FinTech developments for banks and bank supervisors

27 October 2017
The German Banking Industry Committee (GBIC) welcomes the Basel Committee’s initiative to examine the effects of FinTech for banks and banking supervision. From the perspective of German banks, the study is largely comprehensive and accurate, yet it urgently needs ... [ mehr ... ]

Development of secondary markets for non-performing loans and distressed assets and protection of secured creditors from borrowers’ default

20 October 2017
German Banking Industry Committee welcomes the possibility to comment on EU-Commissions Consultation on the development of secondary markets for non-performing loans and distressed assets and protection of secured creditors from borrowers’ default. A crucial factor in creating and evaluating loan ... [ mehr ... ]

Statement on the remarks of the European Commission on EDIS in its communication on ‘completing the Banking Union’ dated October 11, 2017

11 October 2017
The latest comments by the European Commission on a European Deposit Insurance Scheme (EDIS) have not brought about any significant improvement. There are still a number of major shortcomings and aspects requiring clarification. [ mehr ... ]

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