Comments on EBA’s Draft Guidelines on institution’s stress testing
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). The GBIC welcomes the fact that the European Banking Authority (EBA) incorporated some suggestions made in the previous consultation. However, GBIC criticises that important aspects were not adopted. The level of detail of the requirements for institution´s stress testing seems to be very high and this could lead to substantial additional effort for German institutions. In its comments on the Draft guidelines, the GBIC illustrates central points of criticism and replies to the questions on the Draft Guidelines posed by EBA.