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

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.

16/12/2020
vdp-comments

EU Taxonomy Regulation: vdp submits comments on the Delegated Act

With the EU Taxonomy Regulation the EU seeks to channel private capital into sustainable economic activities with a view to achieving the objectives of the Paris Climate Agreement. Technical evaluation criteria have now been drawn up for two of the climate objectives defined in the taxonomy – climate change mitigation and climate change adaptation – for buildings, amongst other things, and have been published for consultation. The aim is for these criteria to be used in the future to identify “green”, taxonomy-compliant economic activities. The criteria will be put into effect through a delegated act that is to be finalized in early 2021. The vdp has examined this matter thoroughly with its expert committees and worded an opinion. The main thrust of the vdp’s comments is that it will hardly be possible at present to implement the evaluation criteria with regard to new buildings, existing properties and renovations. Instead, the vdp calls for practice-oriented criteria which take into account, in particular, the problems of insufficient data availability and the lack of a legal base at the national level.

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.