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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.



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.


January 13, 2016

Credible, sustainable deposit protection / Cooperative Financial Services Network and Savings Banks Finance Group reject pro-posed EDIS for mutualization of deposit insurance in the eurozone

On November 24, 2015, the European Commission put forward its proposal for a regulation to establish a deposit insurance system for the EU member states that belong to the banking union. Its stated aim is to merge national deposit guarantee schemes to form one European deposit insurance system (EDIS) to create a fully-fledged banking union. Deposit insurance in the eurozone is planned to be fully mutualized in three stages from 2017 to 2024 by creating a centralized European deposit insurance fund (DIF). The National Association of German Cooperative Banks (BVR) and the German Savings Banks Association (DSGV) are strongly opposed to any mutualization of deposit insurance within the eurozone, because it is neither necessary nor appropriate. Instead, it would create cross-border liability obligations without any adequate means of (risk) control. Given that current conditions in the individual countries, banks and deposit guarantee funds are very different, the redistribution of risk would result in an uncontrolled transfer union in the area of deposit protection. This would be at the expense of depositors and banks, and ultimately also at the expense of taxpayers in countries with functioning deposit guarantee funds because their liability risk within the eurozone would increase. The consequence would not be more stability and security, it would be further conflict in Europe.

Deutsche Kreditwirtschaft

October 08, 2015

Possible impact of the CRR and CRD IV on bank financing of the economy

Comments on DG FISMA consultation paper on the possible impact of the CRR and CRD IV on bank financing of the economy.

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BVR - 06.05.2014 12:00:00

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