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

03/01/2020
German Banking Industry Committee (GBIC) - comments

Commission's consultation regarding the transposition of the final Basel III reforms in the EU

German Banking Industry Committee (GBIC) comments, among other things, on the standardised approach for credit risk (SA-CR), on the internal ratings based approach (IRBA), on the output floor and on the credit valuation adjustment risk for derivatives (CVA-risk).

03/01/2020
vdp-comments

Commission's consultation regarding the transposition of the final Basel III reforms in the EU

The implementation of the final Basel III requirements should not result in significant increases of capital requirements for German Pfandbrief Banks. Care must be taken to ensure that there is no gold-plating of the output floor. Additionally, the specificities of European property financing should be considered risk-adequately in the EU implementation.

08/08/2019
German Banking Industry Committee (GBIC) - comments

Consultation of the consolidated Basel Framework

German Banking Industry Committee (GBIC) comments, among other things, on the difference between the consolidated Basel framework and previously published standards. In particular, this relates to the output floor introduced via final Basel III reforms and the large exposure treatment of covered bonds (like Pfrandbriefe) held for trading.

19/09/2018
JOINT vdp and Finance Denmark (FIDA) comments

Draft report on the CB Directive and on amending article 129 of the CRR

JOINT vdp and Finance Denmark (FIDA) comments regarding draft reports on proposal for a Covered Bonds directive and exposures in the form of covered bonds (CRR), including:

  • Amendments to Proposal for a Directive on the issue of covered bonds and covered bond public supervision
  • Amendments to Proposal for a Regulation amending Regulation (EU) No 575/2013 as regards exposures in the form of covered bonds
29/08/2018
vdp-comment

Draft report on the CB Directive and on amending article 129 of the CRR

vdp comments to the draft report on a Directive proposal on the issue of covered bonds and covered bond public supervision.