The German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – BaFin) published Circular 13/2019 (BA) on the specification of types of exposures to be associated with high risk under Art. 128 (3) of the Capital Requirements Regulation (CRR), with which it incorporates the European Banking Authority guidelines (EBA/GL/2019/01) into its administrative practice. The circular will enter into force on 1 January 2020. If an institution determines position types in accordance with Section 4.3, Paragraph 7 of the guidelines, it shall communicate this to the BaFin together with a brief description of the most important features of these risk positions. The BaFin shall transmit the information regarding the type of risk position and the characteristics to the EBA in anonymised form. This transposition is not supported by the German Banking Industry Committee (Deutsche Kreditwirtschaft), who argue that redundancy of reporting requirements, unnecessary treatment of real estate financing, impending changes due to the CRR II with regard to venture capital and private equity, and the initiative to harmonise reporting in the EU do not justify the implementation costs of the guidelines in their current form.

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