Comments on the draft EBA Guidelines on Credit Risk Mitigation within the A-IRB

24 May 2019

The German Banking Industry Committee (GBIC) has commented on the draft EBA Guidelines on Credit Risk Mitigation for institutions applying the IRB Approach with own estimates of LGDs. In particular, the GBIC is critical about the provisions with regard to legal opinions for the assessment of legal certainty of movable physical collateral.

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