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Comments on Article 5d (sanctions screening) of the proposal for a regulation on instant credit transfers

26 January 2023
In addition to the comments of 25 November 2022 the GBIC has commented on sanctions aspects of the proposal of the European Commission for a regulation on instant credit transfers. [ Read Article ]

Comments on the European Commission’s proposal for a regulation on instant credit transfers COM(2022) 546 final

14 December 2022
The German Banking Industry Committee (GBIC) has commented on the European Commission’s proposal for a regulation amending Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in euro. [ Read Article ]

Position paper on the digital euro: Setting the course that could fundamentally change Europe's payment system

9 December 2022
If a digital euro is introduced, it must be successful for many reasons: for European citizens and the economy in general, and for European banks and savings banks in particular. [ Read Article ]

BdB Position ESMA Call for Evidence SRD II

6 December 2022
BdB commented on the Call for Evidence on the implementation of Chapter Ia and Article 3j of the Shareholder Rights Directive II. [ Read Article ]

New working paper on Commercial Bank Money Token

5 December 2022
The German Banking Industry Committee (GBIC) have detailed several aspects regarding a Commercial Bank Money Token (CBMT) in a new working paper. [ Read Article ]

EBA/CP/2022/05 Draft Implementing Technical Standards (NPL Transaction Data Templates)

24 November 2022
The European Banking Authority (EBA) launched on 16 May 2022 a public consultation on the draft Implementing Technical Standards (ITS) specifying the requirements for the information that sellers of non-performing loans (NPL) shall provide to prospective buyers, seeking to improve … [ Read Article ]

GBIC comments on EBA draft RTS on groups of connected clients

23 November 2022
Please find attached GBIC‘s comments on EBA’s draft RTS on groups of connected clients. GBIC advocates for a consistent drafting of the RTS which will not lead to further burdens for institutions compared to the already existing EBA guidelines on … [ Read Article ]

GBIC comments on the EBA’s supervisory handbook on the validation of IRB rating systems

2 November 2022
GBIC has commented on the EBA’s supervisory handbook which sets out expectations for the validation of rating systems that institutions use within the internal ratings based approach (IRBA) to determine their own funds requirements. [ Read Article ]

Comments of the Association of German Banks on the capital markets union 2022

17 October 2022
To ensure its global competitiveness, financial stability and not least its economic sovereignty, the European Union urgently needs a deep and less fragmented capital market. [ Read Article ]

Comments - Review of the Guidelines on MIFID II product governance requirements

10 October 2022
In June 2017, ESMA published the "Guidelines on MiFID II product governance requirements", which further specify the requirements of MiFID II and its Delegated Directive with regard to target market determination. [ Read Article ]

GBIC Comments on RTS on groups of connected clients

12 September 2022
GBIC is commenting EBA’s draft RTS on groups of connected clients. [ Read Article ]

Benchmark Regulation – EU Commission’s consultation on third-country benchmarks

6 September 2022
With the introduction of the Benchmark Regulation (BMR), provisions for the use of benchmarks from third-country administrators (third-country benchmarks) have also been introduced. [ Read Article ]

Minimum Social Safeguards of the EU Taxonomy

6 September 2022
The EU Platform on Sustainable Finance consulted its draft report on the Taxonomy’s minimum social safeguards. The German Banking Industry Committee provided comments to the consultation. [ Read Article ]

European Sustainability Reporting Standard

9 August 2022
A European Sustainability Reporting Standard ist currently being developed in the context of the Corporate Sustainability Reporting Directive (CSRD). The initial exposure drafts were published by the European Financial Reporting Advisory Group (EFRAG). The German Banking Industry Committee provided comprehensive … [ Read Article ]

Comments on the call for evidence on an open finance framework

3 August 2022
The German Banking Industry Committee (GBIC) welcomes the opportunity to respond to the call for evidence on the European Commission’s open finance framework initiative. [ Read Article ]

EBA discussion paper on the role of environmental risk in the prudential framework

27 July 2022
The German Banking Industry Committee (GBIC) provided comments on the European Banking Authority’s discussion paper on the role of environmental risk in the prudential framework. In particular, the GBIC advocates for a risk-based approach. [ Read Article ]

FSB report on supervisory and regulatory approaches to climate-related risks: GBIC response

30 June 2022
GBIC response on the FSB interim report on climate-related risks. [ Read Article ]

GBIC comments on the targeted consultation on the digital euro

14 June 2022
The German Banking Industry Committee (GBIC) commented on the European Commission’s consultation on a digital euro. [ Read Article ]

GBIC comments on the targeted consultation on improving the EU’s macroprudential framework for the banking sector

19 May 2022
This review should take into account the regulatory initiatives of the last years. A holistic approach is needed. [ Read Article ]

Comments of the German Banking Industry Committee on the European Data Act proposal

13 May 2022
The German Banking Industry Committee (GBIC) welcomes the objective pursued by the proposal for a European Data Act, namely to establish a horizontal legal framework to facilitate the access to data for, and the exchange of data between, consumers and … [ Read Article ]

Position Paper on the EU Regulatory Framework for Artificial Intelligence

11 May 2022
In April 2021, the European Commission presented its proposal for regulating artificial intelligence (AI). This proposal is also crucially important to the German economy. [ Read Article ]

ESMA Consultation on the „Guidelines on certain aspects of the MiFID II suitability requirements“

27 April 2022
The German Banking Industry Committee (GBIC) submitted their responses to the consultation paper published by the European Securities and Markets Authority (ESMA). [ Read Article ]

European Single Access Point

7 April 2022
We are generally in favour of standardised, uniform and database-based reporting which is readable for both humans and machines. We also welcome the associated aims, especially that of creating comparability across businesses. [ Read Article ]

GBIC comments on EBA consultations on interest rate risk in the banking book

28 March 2022
GBIC has submitted comments on three EBA consultation papers on interest rate risk in the banking book (IRRBB). [ Read Article ]

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