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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

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

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.


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.


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.

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BVR - 06.05.2014 12:00:00

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