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
Revision of the ECB Guide to internal models
The revision of the supervisory guide takes into account changes to the regulatory requirements of recent years, implements the need for more specific details that has become evident in on-site inspections and includes new elements. The new elements also cover supervisory expectations to include relevant and material climate-related and environmental risks in the internal models. In detail, however, GBIC sees a wide range of adjustment needs for the general requirements for all internal models and for the specific model requirements for credit risk and counterparty credit risk.
EU Commission consults on macroprudential framework in banking supervision and regulation
The German Banking Industry Committee highlights that the numerous reforms since the great financial crisis have resulted in a robust and resilient banking system, so that the necessary reform of the macroprudential framework must not lead to a global increase in capital requirements. Moreover, the requirements should be simplified and standardised. Simultaneously, greater flexibility and transparency are needed.
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.
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.
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.