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

06/01/2022
vdp comments

COM seeks feedback on CRR amendments to implement Basel IV

At the end of October 2021, the EU Commission (COM) published the EU Banking Package 2021, which includes, among other things, proposals for amending the Capital Requirements Regulation (CRR) and is focused on the EU implementation of the Basel III reform (also known as Basel IV in the banking industry). vdp criticises in particular the significant increase in capital requirements, which results primarily from the overfulfilment of the Basel output floor requirements, and calls for improvements to limit the negative effects.

21/12/2021
GBIC comments

COM seeks feedback on CRD amendments to implement Basel IV and on ESG and other aspects

At the end of October 2021, the EU Commission (COM) published the EU Banking Package 2021, which includes proposals to amend the Capital Requirements Directive (CRD) and is related to the EU implementation of the Basel III reform (also known as Basel IV in the banking industry), addresses the management and supervision of ESG risks and other topics. The German Banking Industry Committee (GBIC) calls for improvements to the supervisory monitoring and evaluation process (SREP), ESG risk management, stress testing and Pillar 2 capital requirements.
 

21/12/2021
GBIC comments

COM seeks feedback on CRR amendments i.e. to implement Basel IV and on ESG

At the end of October 2021, the EU Commission (COM) published the EU Banking Package 2021, which includes, among other things, proposals for amending the Capital Requirements Regulation (CRR) and is focused on the EU implementation of the Basel III reform (also known as Basel IV in the banking industry) and on aspects relating to ESG risks. The German Banking Industry Committee (GBIC) criticises in particular the significant increase in capital requirements, which results primarily from the overfulfilment of the Basel output floor requirements, and calls for improvements to limit the negative effects.

28/09/2021
German Banking Industry Committee Comment

GBIC welcomes proposal for an EU standard for green bonds – further revisions necessary

The German Banking Industry Committee welcomes the European Commission's proposal for an EU standard for green bonds. As part of the European Green Deal, it is of the utmost importance that the EU standard for green bonds is established in a practical manner. Several amendments to the proposed regulation are necessary to enable issuers to help stimulate the green bond markets and to make the European Green Deal a reality.

30/07/2021
German Banking Industry Committee Comment

EBA consults RTS specifying how to set higher risk weights and minimum LGDs for real estate exposures

In line with its mandate in the Capital Requirements Regulation CRR, the European Banking Authority EBA consults on a Regulatory Technical Standard (RTS) specifying conditions under which the authorities designated by the respective EU member states (Federal Financial Supervisory Authority, BaFin, in Germany) can set higher risk weights in the standardised approach for credit risk or higher minimum LGDs in the advanced IRBA for real estate exposures, if required.