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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.



February 02, 2021



Deutsche Kreditwirtschaft

January 16, 2020

Implementing the final Basel III reforms in the EU

Comments on the European Commission’s public consultation on implementing the final Basel III reforms in the EU

Deutsche Kreditwirtschaft

October 08, 2019

EBA Guidelines on loan origination and monitoring

GBIC has responded to EBA‘s draft guidelines on loan origination and monitoring.


June 25, 2019

Proportionality in European banking regulation

The issue of "proportionality in banking regulation" is being discussed increasingly between practitioners, academics and many regulators. To support these discussions and with a view to the upcoming implementation of the finalization of Basel III in the European Union, which requires a significantly higher degree of proportionality than previously required, the BVR together with cooperative associations from the United Kingdom, Austria, Italy, Spain, Poland and Luxembourg drafted a position paper. In addition to findings from groundbreaking studies in Europe, international developments and findings are also considered. The paper concludes that greater proportionality in the area of regulation is possible, necessary and appropriate.


February 08, 2019

Our 10 positions on the European elections 2019

Europe has the choice: on May 26th, citizens in Germany are called upon to decide on the composition of the European Parliament. With the position paper "Strengthening medium-sized banks in Europe", the BVR presents its positions on the European elections - ten positions in order to achieve a more SME-oriented financial market policy in Europe over the next few years.

Deutsche Kreditwirtschaft

November 05, 2018

Directive on representative actions

Accompanying the draft report of the committee on Legal Affairs of the European Parliament 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 fundamental rights and to prevent abuse of representative actions the Proposal should in particular take into account the aspects described in the Position Paper.

Deutsche Kreditwirtschaft

September 25, 2018

EBA Guidelines on Outsourcing

On 22 June 2018, the EBA published a consultation paper on its Guidelines on Outsourcing arrangements. The German Banking Industry Committee (GBIC) appreciates the opportunity to comment. The GBIC believes that the obligations for institutions proposed in the Draft guidelines go too far overall. Inter alia, the requirements do not distinguish sufficiently between the outsourcing of critical and of non-critical functions. There is a risk that institutions will no longer be able to exploit the opportunities offered by outsourcing because of the high administrative effort.

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.

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.


August 09, 2018

Regulation on disclosures relating to sustainable investments and sustainability risks

The BdB, BVR and DSGV associations support the start made by the European Commission on promoting sustainable investment products. Sustainable investments are of growing importance on the German market, which is why the German banks and savings banks are addressing the issue in depth. The legislative initiative of the European Commission offers the opportunity to eliminate some of the barriers for issuers and distributors and in this way to broaden the dissemination of sustainable products. For this reason, we appreciate the opportunity to comment on this draft.

Mehr anzeigen
BVR - May 6, 2014, 12:00:00 PM

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