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Our Comments

The BVR regularly releases comments and statements on topical aspects of financial market regulation, which it publishes by itself or in conjunction with other associations in the financial services sector. Only selected statements of opinion are available here in English.

 




Deutsche Kreditwirtschaft

August 13, 2018

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

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. We appreciate the opportunity to submit our comments.


Deutsche Kreditwirtschaft

August 13, 2018

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

The European Banking Authority (EBA) published its "Draft Guidelines on disclosure of non-performing and forborne exposures" for consultation on 27 April 2018. We appreciate the opportunity to submit our comments.


BVR

March 09, 2017

Stability through diversity - Comments from BVR, DSGV, EACB und WSBI

Appropriate regulation, differentiated according to risk content and size, which takes account of their importance for the economy and for society – this is what savings banks and co-operative banks called for in a common position.


Deutsche Kreditwirtschaft

October 12, 2016

Payment Services Directive

Response to the EBA Consultation Paper on the draft Regulatory Technical Standards specifying the requirements on strong customer authentication and common and secure communication under PSD2.


Deutsche Kreditwirtschaft

September 06, 2016

CRD/CRR review

Position paper on adjustment of the European large exposure rules in the CRD/CRR review


Deutsche Kreditwirtschaft

September 01, 2016

Anti-Money Laundering Directive

Comments on the European Commission proposal for a directive amending the Fourth Anti-Money Laundering Directive.


Deutsche Kreditwirtschaft

August 31, 2016

Net Stable Funding Ration

Position on the implementation of the Net Stable Funding Ration (NSFR) in the EU


Deutsche Kreditwirtschaft

August 17, 2016

Analytical Credit Datasets

AnaCredit is a project to set up a dataset containing detailed information on individual bank loans in the euro area, harmonised across all Member States. The data collection is scheduled to start in September 2018. In view of the large number of questions raised by implementation of AnaCredit, the DK took the opportunity to comment on the draft AnaCredit Manual.


Deutsche Kreditwirtschaft

July 22, 2016

Leverage Ratio

Position paper from German Banking Industry Committee and Austrian Economic Chamber – Division Bank and Insurance - on the implementation of the leverage ratio in Europe – comments on the analysis commissioned under Article 511 of the CRR.


Deutsche Kreditwirtschaft

February 02, 2016

EU Regulatory Framework for Financial Services

In its response to a consultation by the European Commission, the German Banking Industry Committee (GBIC) criticises “unnecessary burdens” arising from new banking regulation. The costs generated by implementing the regulatory requirements pose a significant challenge, especially for small banks. GBIC is highly critical of the excessively short periods granted to implement many regulatory requirements.




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BVR - 06.05.2014 12:00:00
URL: https://www.bvr.de/Unsere_Positionen/Stellungnahmen

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