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GBIC comments on the EBA’s consultation on its guidelines on overall recovery capacity

The GBIC is critical that the guidelines focus solely on overall recovery capacity for peer group comparison. Instead, the focus should be on identifying optimal recovery strategies for each bank. In addition, the content overlaps with existing EBA guidelines.
 

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EBA Consultation Paper

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GBIC comments on the EBA Discussion paper

Simplification and assessment of the credit risk framework

The German Banking Industry Committee welcomes the initiative of the European Banking Authority (EBA) to explore possible avenues for simplifying the existing credit risk framework.