2. Comments

Position paper on strengthening the role of the European Union in a global context

17 April 2019
For decades, the economic integration of the European Union (EU) has been successfully driven forward in order to secure and promote prosperity and stability in Europe. At the same time, the EU is increasingly pursuing a common trade policy within ... [ mehr ... ]

A stronger international role of the euro benefits Europe's economy

16 April 2019
An even stronger role for the euro in international markets would increase the EU’s independence and be good for companies in Europe. To give the European single currency a boost, capital markets and banking union should be moved forward ... [ mehr ... ]

Proportionality in banking regulation – discussions have to continue: “after the CRR/CRD review is before the CRR/CRD review”

4 April 2019
Since the 2008 financial crisis a number of new laws,rules and regulations have been introduced to increase the stability of the financial system and the protection of public funds. [ mehr ... ]

Know Your Customer: Corporate customer verification in the Single Market

20 March 2019
The digital transformation is one of the key challenges today – also for the financial industry. The Association of German Banks is meeting this challenge by, among other things, cooperating with start-ups from the financial sector, fintechs. [ mehr ... ]

Comments on Revisions to leverage ratio disclosure requirements

13 March 2019
The Basel Committee’s additional leverage ratio disclosure requirements are designed to reflect its concerns about “window-dressing”. The Basel Committee would like to see averaged values disclosed on the basis of values calculated daily. [ mehr ... ]

DK comments on EBA’s Consultation Paper on Draft ITS amending Commission Implementing Regulation (EU) 2016/2070 with regard to benchmarking of internal models

30 January 2019
DK comments on the above-mentioned EBA consultation paper. The EBA changes the ITS requirements in both the credit risk and market risk areas. The exercise is relevant for institutions with IRB models or IMA models (market risk models) in Pillar ... [ mehr ... ]

IASB Discussion Paper Financial Instruments with Characteristics of Equity

21 December 2018
In July 2018 the IASB has published a discussion paper due to the distinction between liabilities and equity for financial instruments. In its comment letter, the GBIC criticizes the complexity of the IASB proposals and advocates for selective amendments of ... [ mehr ... ]

Position paper on further development of the EU equivalence regime

12 November 2018
The decision of the UK to leave the EU entails the need to qualify an entire EU submarket as a third country at once. The existing EU equivalence rules have so far only been anchored sectorally in EU legislation. [ mehr ... ]

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 ... ]

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