The Bankers Association regularly publishes position papers summarising the position of private banks on a wide range of topics. We also participate in legislative processes by issuing statements. Here you will find all current contributions from all specialist areas at a glance.

Die Deutsche Kreditwirtschaft begrüßt das Vorhaben der Bundesregierung, den Anlegerschutz im Bereich der Vermögensanlagen weiter auszubauen. Auf die Notwendigkeit entsprechender Schritte haben wir seit Jahren angesichts von Missständen und Fehlentwicklungen in dem Bereich hingewiesen.&nbsp;

Die D

Stellungnahme zum Referentenentwurf für ein Gesetz zur Verbesserung des Anlegerschutzes bei Vermögensanlagen (AnlVerG) 

The German Banking Industry has issued a statement on the Basel Committee on Banking Supervision's (BCBS) discussion paper on the role of climate scenario analysis in strengthening the management and supervision of climate-related financial risks. The discussion paper of the Basel Committee on Banki

„BCBS – DP on the roleof climate scenario analysis (CSA) in the management and supervision of climate-related financial risks“ 

Inhalt

Introduction
What are transition plans?
What is the purpose of transition plans?
What is good practice in the drafting of transition plans?
Conclusions

Introduction

Initially, the EU sustainable finance framework focused on defining, through the EU taxonomy, which economic activi

A Practical Overview of Businesses’ Transition Plans for Banks 

Europe is more important than ever. An open, democratic Europe is not only essential for our cohesion and our social progress, but also vital for our economy. The private banks are demonstrating how competitive and attractive Europe can be, also in the future – for its citizens, the economy and a st

Strengthening Europe and its financial sector - an agenda until 2029

Summary

Deep and efficient EU financial markets are vital for the financing of the EU’s upcoming challenges – in particular, the transformation or transition of our economy. This realisation, and as a result, the goal of completing EU capital markets union is gaining increasing support. However, 

Position paper on deepening the capital markets

On January 18, the European Banking Authority (EBA) published a consultation paper on the management of ESG risks.
The German Banking Industry Committee (DK) has therefore today submitted a statement to the European Banking Authority on the consultation paper "Draft Guidelines on the management of 

DK Konsultation | EBA Draft Guidelines on the management of ESG risks

Looking to the future – optimising the production line for securitisations

In the coming years, European society will face the enormous challenge of rapidly advancing the green and digital transformation of the economy with investments worth billions of euros. The EU Commission estimates that the

Position paper on securitisations

The German Banking Industry Committee (GBIC) has submitted a statement to the Basel Committee on Banking Supervision (BCBS) on the consultation document "Recalibration of shocks for interest rate risk in the banking book (IRRBB)".

GBIC considers a regular inspection of the calibration of interest

Comments on BCBS Consultation Paper “Recalibration of shocks for interest rate risk in the banking book”

BdB has commented on the consultation of the European Securities and Markets Authority ESMA on shortening the settlement cycle to T + 1.


Reply form on the call for evidence on shortening of the settlement cycle

In early January 2024, the European Supervisory Authorities (ESAs) presented the draft of their technical implementing standards outlining certain tasks of collection bodies and functionalities of the central European Access Portal (ESAP) for consultation. With the establishment of ESAP as a central

GBIC comments on ESA’s

BdB position paper on the ESMA consultation on penalties under the CSDR.


Reply Form to the Consultation Paper on Technical Advice on CSDR Penalty Mechanism

Content

Management Summary
1. DeFi – a financial revolution?
2. DeFi – examples of use cases
3. “Institutional DeFi” – how banks might get involved in the DeFi market
4. Opportunities and risks of the DeFi market for users and banks
5. Status quo: DeFi from today’s regulatory perspective
6.

Discussion paper Decentralised Finance – an evolution of the financial services sector?

The German Banking Industry Committee (GBIC) welcomes the European Commission’s goal of a 25 percent reduction in the burden on companies and administrative organizations resulting from reporting requirements.


Comments regarding the European Commission's consultation exercise "rationalisation of reporting requirements"

The European Banking Authority (EBA) launched a public consultation in July 2023 on its Draft Guidelines on the establishment and maintenance of national lists or registers of credit servicers under Directive 2021/2167. The proposed Guidelines specify the types of information that national lists or 

Comments on EBA’s Draft Guidelines on the establishment and maintenance of national lists or registers of credit servicers

The European Commission has presented its proposals on the draft legislation for the revision of the second EU Payment Services Directive (PSD2) on 28 June 2023. The German Banking Industry (DK) welcomes the fact that essential provisions of the previous regulations will be retained. On the one hand

Positions & Comments