GBIC comments on ECB Guide to Internal Models

7 November 2018
Based on the 2017 TRIM Guide (Targeted Review of Internal Models) the ECB drafted a revised Guide to Internal Models. It sets out detailed rules regarding the use of internal credit, market and counterparty risk models to calculate own funds ... [ mehr ... ]

Position Paper on the Proposal of the European Commission for a Directive on representative actions

31 October 2018
Accompanying the draft report of the committee on Legal Affairs of the European Parliament (JURI) of 12 October 2018 the German Banking Industry Committee (GBIC) outlines core requirements on the introduction of European representative actions. In order to ensure basic ... [ mehr ... ]

Comments on Draft EBA Guidelines on Outsourcing

24 September 2018
On 22 June 2018, the EBA published a consultation paper on its Guidelines on Outsourcing arrangements (EBA/CP/2018/11). [ mehr ... ]

Strong banks for a single European financial market

28 August 2018
To strengthen EU banks, a large home market – a single European financial market – needs to be created for them. Thanks to its uniform rules, such a market would allow economies of scale, enabling banks to cut their costs. [ mehr ... ]

Comments on the proposal for a regulation on the establishment of a framework to facilitate sustainable investment

22 August 2018
The German Banking Industry Committee (GBIC) supports the European Commission’s initiative to raise more funding for a sustainable economy in Europe and to promote financial market stability. [ mehr ... ]

Comments on EBA guidelines on STS criteria (securitisation)

30 July 2018
GBIC has commented EBA’s consultation on guidelines on STS criteria for ABCP and non-ABCP criteria. [ mehr ... ]

Comments on the Proposal of the European Commission for a Directive on representative actions to protect the collective interests of consumers

27 July 2018
In the opinion of the German Banking Industry Committee (GBIC), there is no need for a European initiative to introduce representative actions to protect the collective interests of consumers. [ mehr ... ]

Comments on the EBA Draft Guidelines on disclosure of non-performing and forborne exposures

27 July 2018
The European Banking Authority (EBA) published its “Draft Guidelines on disclosure of non-performing and forborne exposures” for consultation on 27 April 2018. [ mehr ... ]

Comments on the EBA Draft Guidelines on specification of types of exposures to be associated with high risk

17 July 2018
The European Banking Authority (EBA) issued its Draft Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of Regulation (EU) No 575/2013 for consultation on 17 April 2018. [ mehr ... ]

Position paper Know your Customer: Retail customer verification in the Single Market

4 July 2018
A feature of many banks and fintechs is that they operate across national borders. The primary focus here is on the so-called ‘know your customer’ (KYC) processes. [ mehr ... ]

GBIC Comments: EBA Draft RTS on the specification of the nature, severity and duration of an economic downturn and EBA Draft Guidelines for the estimation of LGD appropriate for an economic downturn

22 June 2018
DK comments on two EBA consultation papers on the so-called Downturn LGD. On the one hand, the revised RTS draft for determining the economic downturn period is commented. [ mehr ... ]

DK on the planned amendment of MiFID II

21 June 2018
On 21 June 2018, the German Banking Industry Committee (DK) commented on the planned amendment of MiFID II. GBIC supports the EU Commission's efforts to promote sustainable finance. [ mehr ... ]

GBIC Comments – Revisions to the minimum capital requirements for mark

20 June 2018
DK comments on the Basel consultation paper on the revision of the Basel market risk rules. The standardised approach (SBA approach), the simplified standardised approach, the model approach (IMA) and the scope of the revised market risk rules are being ... [ mehr ... ]

Banks and Fintechs: The Case for Outsourcing

18 June 2018
The financial sector is a key part of the economy. As part of this sector, banks operate in an ecosystem in which they increasingly provide products and services in cooperation with third parties. [ mehr ... ]

Post-PSD2: Use of data between added value for customers and data sovereignty

12 June 2018
The digitisation of business processes brings many benefits not only for businesses but particularly also for citizens: using data-based analyses, their behaviour and thus also their wishes and needs can be better ‘understood’. [ mehr ... ]

Comments on the EBA Draft Guidelines on management of non-performing and forborne exposures

8 June 2018
The German Banking Industry Committee (GBIC) has commented on the“Draft Guidelines on management of non-performing and forborne exposures” published for consultation by the European Banking Authority (EBA) on 8 March 2018. [ mehr ... ]

Comments on the draft ECB guide to internal models – General topics chapter

28 May 2018
The German Banking Industry Committee (GBIC) has commented on the draft ECB guide to internal models – General topics chapter as part of the ECB's public consultation. [ mehr ... ]

Comments on the European Commission’s proposal for a Regulation of the European Parliament and the Council on amending Regulation (EU) No 575/2013 as regards minimum loss coverage for non-performing exposures

25 May 2018
The European Commission (COM) published a proposal for a Regulation on amending Regulation (EU) No 575/2013 as regards minimum loss coverage for non-performing exposures on 14 March 2018. We appreciate the opportunity to submit our comments. [ mehr ... ]

Comments on the BCBS Pillar 3 disclosure requirements – updated framework

25 May 2018
The Basel Committee on Banking Supervision (BCBS) issued on 27 February 2018 a consultative document on the updated Pillar 3 disclosure requirements framework. [ mehr ... ]

EFRAG Discussion Paper Equity instruments – Impairment and Recycling

24 May 2018
EFRAG has published a discussion paper where alternative rules for accounting of equity instruments according to IFRS 9 (FV-OCI) are discussed. The GBIC sees currently no need for changes. [ mehr ... ]

Use of data: balancing added value for customers and data protection

23 May 2018
The Association of German Banks is meeting this challenge by, among other things, cooperating with start-ups from the financial sector, fintechs. The present paper is the result of intensive cooperation between banks and fintechs. [ mehr ... ]

Comments on the European Commisssion's proposal for a Directive on the issue of covered bonds and covered bond public supervision & proposed Regulation on amending Regulation (EU) 575/2013 as regards exposures in the form of covered bonds

15 May 2018
The German Banking Industry Committee (GBIC) has commented on the EU-Commission’s proposal for a Directive on the issue of covered bonds and covered bond public supervision & on a proposal for a Regulation on amending Regulation (EU) 575/2013 as ... [ mehr ... ]

Comments of the German Banking Industry Committee on the European Commission's legislative proposal for a Regulation on facilitating cross-border distribution of investment funds and a Directive on cross-border distribution of investment funds

9 May 2018
On 12 March 2018, the European Commission published two legislative proposals to remove obstacles to the cross-border distribution of investment funds and asked for feedback. GBIC commented on this on May 9, 2018. [ mehr ... ]

Comments on the Draft Commission Implementing Regulation laying down minimum requirements implementing the provisions of Directive 2007/36/EC

9 May 2018
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 identification, the transmission of information ... [ mehr ... ]

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