Press > Publications
Comments
The vdp is one of the five associations that make up the German Banking Industry Committee (GBIC). The GBIC develops common banking-industry positions on issues relating to banking law, banking policy, and banking practice. It conveys the banking industry’s common standpoints to legislators, the government, authorities, as well as banking and financial-sector institutions at the national, European and international levels.
The vdp’s positions are therefore regularly incorporated in GBIC comments, which are available on its website. Below you’ll find select comments by the vdp on statutory changes that concern Pfandbriefe and the underlying business sectors of Pfandbrief banks.
Comments
German Banking Industry Committee Comment
EU Taxonomy: GBIC comments to amendments of delegated acts
The core proposal of the GBIC is to make the EU Taxonomy more practical and efficient, aiming to relieve both the financial sector and the real economy while promoting sustainability objectives.
German Banking Industry Committee Comment
TSI/DK response to the EU COM consultation on the securitization framework
TSI and Deutsche Kreditwirtschaft (DK) answer more than 150 questions from the European Commission on the functioning of the securitization framework. From the point of view of the TSI and DK, there is now a need for action. A series of measures are necessary that together will increase the potential of securitization and thus strengthen competitiveness in Europe.
German Banking Industry Committee Comment
DK statement on the EBA consultation “draft Guidelines on ADC exposures to residential property under CRR 3” (EBA/CP/2024/12)
In May 2024, the European Banking Authority (EBA) launched a consultation on its draft guidelines on ADC exposures for residential real estate in accordance with Art. 126a CRR III. These guidelines define, among other things, the terms “appropriate amount of capital contributed by the obligor” and “significant proportion of total contracts”, which allow institutions to assign a risk weight of 100% instead of 150% to ADC loans for residential real estate.
German Banking Industry Committee Comment
DK statement on the EBA consultation EBA/CP/2024/08 RTS
DK statement on the EBA consultation EBA/CP/2024/08 RTS on the allocation of off-balance sheet items and UCC considerations
The DK sees the consultation on the treatment of off-balance sheet items as a welcome opportunity to clarify the classification of selected products.
DK Consultation | EBA Draft Guidelines on the management of ESG risks
On January 18, the European Banking Authority (EBA) published a consultation paper on the management of ESG risks. The German Banking Industry (DK) has therefore today submitted a statement to the European Banking Authority on the consultation paper “Draft Guidelines on the management of ESG risks”. In its statement, the German Banking Industry asks for the elimination of existing ambiguities and prepares proposals for changes to the planned guideline.
In particular, investment plans and proportionality are addressed. Details can be found in the statement.
German Banking Industry Committee Comment
Revision of the ECB Guide to internal models
The revision of the supervisory guide takes into account changes to the regulatory requirements of recent years, implements the need for more specific details that has become evident in on-site inspections and includes new elements. The new elements also cover supervisory expectations to include relevant and material climate-related and environmental risks in the internal models. In detail, however, GBIC sees a wide range of adjustment needs for the general requirements for all internal models and for the specific model requirements for credit risk and counterparty credit risk.
Contact
Further Information