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.
EBA-Consultation, Draft Regulatory Technical Standards
EBA Consultation Papers: Draft Regulatory Technical Standards on the specification of the nature, severity and duration of an economic downturn in accordance with Articles 181(3)(a) and 182(4)(a) of Regulation (EU) No 575/2013 (EBA/CP/2018/07); Guidelines for the estimation of LGD appropriate for an economic downturn (‘Downturn LGD estimation’) (EBA/CP/2018/08)
Revisions to the minimum capital requirements for market risk
On March 22, 2018, the Basel Committee on Banking Supervision issued the “Revisions to the minimum capital requirements for market risk” for consultation.
Finalisation of Basel III (SA-CR, IRB, output floor)
European Commission’s “Exploratory consultation on the finalisation of Basel III” (Online Questionnaire). vdp’s responses to this consultation focus specifically on the revisions to the standardised approach for credit risk (SA-CR), the revisions to both internal ratings-based approaches for credit risk (IRB) and the replacement of the “Basel II” floor with the aggregate output floor. Special emphasis is placed to some aspects in the treatment of real estate lending.
Finalisation of Basel III
Comments on the European Commission’s “Exploratory consultation on the finalisation of Basel III” (Online Questionnaire)
Internal Ratings-Based (IRB) Approach, Standardised Approach for credit risk (SA)
Basel Committee on Banking Supervision, Consultative Documents, Reducing variation in credit risk-weighted assets – constraints on the use of internal model approaches, Revisions to the Standardised Approach for credit risk