Comments on Draft Guidelines on the appropriate subsets of exposures in the application of the systemic risk buffer

23 July 2020

The German Banking Industry Committee (GBIC) has issued its comments to the public consultation of the European Banking Authority (EBA) on the draft guidelines on the appropriate subsets of exposures in the application of the systemic risk buffer. In general, GBIC welcomes EBA’s draft paper which aims to create a common framework for competent national authorities with regard to the implementation of sectoral systemic risk buffer and the envisaged increase in flexibility and precision of the buffer. However, the complexity of the guideline should be reduced, the avoidance of multiple capital backing for systemic risk should be guaranteed and the transparency of decisions and associated processes should be increased.

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