The Bankers Association regularly publishes position papers summarising the position of private banks on a wide range of topics. We also participate in legislative processes by issuing statements. Here you will find all current contributions from all specialist areas at a glance.

On January 18, the European Banking Authority (EBA) published a consultation paper on the management of ESG risks.
The German Banking Industry Committee (DK) has therefore today submitted a statement to the European Banking Authority on the consultation paper Draft Guidelines on the management of 

DK Konsultation | EBA Draft Guidelines on the management of ESG risks

Looking to the future – optimising the production line for securitisations

In the coming years, European society will face the enormous challenge of rapidly advancing the green and digital transformation of the economy with investments worth billions of euros. The EU Commission estimates that the

Position paper on securitisations

The German Banking Industry Committee (GBIC) has submitted a statement to the Basel Committee on Banking Supervision (BCBS) on the consultation document Recalibration of shocks for interest rate risk in the banking book (IRRBB).

GBIC considers a regular inspection of the calibration of interest

Comments on BCBS Consultation Paper “Recalibration of shocks for interest rate risk in the banking book”

BdB has commented on the consultation of the European Securities and Markets Authority ESMA on shortening the settlement cycle to T + 1.


Reply form on the call for evidence on shortening of the settlement cycle

In early January 2024, the European Supervisory Authorities (ESAs) presented the draft of their technical implementing standards outlining certain tasks of collection bodies and functionalities of the central European Access Portal (ESAP) for consultation. With the establishment of ESAP as a central

GBIC comments on ESA’s

BdB position paper on the ESMA consultation on penalties under the CSDR.


Reply Form to the Consultation Paper on Technical Advice on CSDR Penalty Mechanism

Content

Management Summary
1. DeFi – a financial revolution?
2. DeFi – examples of use cases
3. “Institutional DeFi” – how banks might get involved in the DeFi market
4. Opportunities and risks of the DeFi market for users and banks
5. Status quo: DeFi from today’s regulatory perspective
6.

Discussion paper Decentralised Finance – an evolution of the financial services sector?

The German Banking Industry Committee (GBIC) welcomes the European Commission’s goal of a 25 percent reduction in the burden on companies and administrative organizations resulting from reporting requirements.


Comments regarding the European Commissions consultation exercise rationalisation of reporting requirements

The European Banking Authority (EBA) launched a public consultation in July 2023 on its Draft Guidelines on the establishment and maintenance of national lists or registers of credit servicers under Directive 2021/2167. The proposed Guidelines specify the types of information that national lists or 

Comments on EBA’s Draft Guidelines on the establishment and maintenance of national lists or registers of credit servicers

The European Commission has presented its proposals on the draft legislation for the revision of the second EU Payment Services Directive (PSD2) on 28 June 2023. The German Banking Industry (DK) welcomes the fact that essential provisions of the previous regulations will be retained. On the one hand

Comments on the European Commissions legislative proposals of 28 June 2023 to revise the Second Payment Services Directive

The European Banking Authority (EBA) launched a public consultation in July 2023 on draft templates and template guidance for collecting climate related data from EU banks. This effort is part of the one-off Fit-for-55 climate risk scenario analysis. The draft templates are designed to collect clima

GBIC comments on EBA’s draft templates and template guidance for collecting climate related data from EU banks

The consultation by the Financial Stability Board (FSB) “on the effects of G20 financial regulatory reforms on securitisation” is the start of a global discussion on the review of the securitisation framework. We believe it has become an urgent matter, both in terms of the timing and the content, to

Comments on FSB consultation: Evaluation on Effects of G20 Reforms on Securitisation 

The European Central Bank (ECB) launched a public consultation in July 2023 on its Guide on effective risk data aggregation and risk reporting. The guide details supervisory expectations for governance and risk management and shares best industry practices. Banks are expected to step up and conclude

GBIC comments on ECB’s Guide on effective risk data aggregation and risk reporting

The German Banking Industry Committee (Die Deutsche Kreditwirtschaft) welcomes the fact that the Basel Committee on Banking Supervision is revising its principles for effective banking supervision in order to address supervisory and regulatory developments, structural changes in the banking system, 

Comments of the German Banking Industry Committee on the BCBS-Consultative Document Core principles for effective banking supervision

The German Banking Industry Committee (Die Deutsche Kreditwirtschaft – DK) welcomes the “Post-implementation Review IFRS 9 Financial Instruments Impairment” and notes that the implementation of the impairment rules of IFRS 9 has been a very high effort for the banks. In many banks, IFRS 9 was the la

Positions & Comments