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

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.

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