Comments

GBIC comments draft SREP guidelines and supervisory stress testing (EBA/CP/2021/26)

GBIC welcomes the decision to update the SREP Guidelines. We also agree with the overarching objectives, namely (a) to increase convergence of practices followed by competent authorities across the EU, and (b) to align the SREP Guidelines with other relevant EBA guidelines and technical standards. Nevertheless, the draft version of the Guidelines contains specific provisions that go further than the EU Directive (CRD). In addition, the scope of provisions set out in the Guidelines has been expanded yet again. We fear that this could further eclipse proportionality issues under Pillar 2.

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Stellungnahme SREP-Leitlinien

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GBIC comments on amending Delegated Regulation (EU) 2019/98

The German Banking Industry Committee (GBIC) welcomes the objective of revising Commission Delegated Regulation (EU) 2019/980 to simplify prospectus requirements, streamline their content and further standardise format and structure, thereby reducing administrative burdens for issuers, improving comparability for investors and strengthening access to EU capital markets.