The Deutsche Bundesbank (BBk) published a circular to remind AnaCredit reporting agents that the reporting of data with respect to natural persons is not in accordance with the ECB and national regulation. Reporting of data by natural persons is not covered by statistical reporting requirements. A contractual partner in the context of AnaCredit is an institutional entity that is a legal entity or part of a legal entity, i.e., a legal partnership (Gesellschaft bürgerlichen Rechts - GbR) incorporated under civil law. Such a GbR with legal capacity only exists if it is a so-called "external GbR” in contrast to the so-called "internal GbR".

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