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

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.

24/08/2018
German Banking Industry Committee (GBIC) - comments

European Commission’s Proposal for a Regulation on sovereign bond-backed securities

With its proposal to introduce sovereign bond-backed securities (SBBSs), the European Commission hopes to offer an opportunity for weakening the bank-sovereign nexus. However, SBBSs are not the only proposal for solving this problem, although other proposals such as capital requirements for sovereign bonds are highly controversial, so a further proposal appears to make sense here. The GBIC therefore notes with interest the European Commission’s proposal. However, there are numerous elements in the proposal that call its practicability into question.

22/08/2018
German Banking Industry Committee - comments

framework to facilitate sustainable investment

Comments on the proposal for a regulation on the establishment of a framework to facilitate sustainable investment. The German Banking Industry Committee (GBIC) supports the European Commission’s initiative to raise more funding for a sustainable economy in Europe and to promote financial market stability. To achieve these objectives, it is essential to establish a common understanding of which type of economic activity is to be designated as “sustainable”. In this respect, we welcome the European Commission’s initiative to draw up a classification at EU level based on existing international frameworks.

22/06/2018
German Banking Industry Committee-comments

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)