Many thanks to Frankfurt Main Finance and VIB – Association of International Banks in Germany for the opportunity to contribute to this 𝗙𝗼𝗼𝗱 𝗳𝗼𝗿 𝗧𝗵𝗼𝘂𝗴𝗵𝘁 video session!
It was a great discussion about the impact of CRD VI and BRUBEG on third-country banks seeking market access to the EU and Germany.
Here are the key takeaways:
- 𝗟𝗲𝘃𝗲𝗹 𝗽𝗹𝗮𝘆𝗶𝗻𝗴 𝗳𝗶𝗲𝗹𝗱: For core banking services, CRD VI harmonises the rules for third-country entities seeking market access in the EEA.
- Review 𝗼𝗳 𝗺𝗮𝗿𝗸𝗲𝘁 𝗮𝗰𝗰𝗲𝘀𝘀 𝘀𝘁𝗿𝗮𝘁𝗲𝗴𝗶𝗲𝘀: The harmonisation of third-country rules calls into question the existing country-by-country approaches of non-EEA banking groups.
- 𝗘𝘅𝗶𝘀𝘁𝗶𝗻𝗴 𝗿𝗲𝗴𝗶𝗺𝗲: Germany’s existing regime for third-country entities is already comparatively strict.
- 𝗟𝗶𝗺𝗶𝘁𝗮𝘁𝗶𝗼𝗻 𝗼𝗳 𝘄𝗮𝗶𝘃𝗲𝗿𝘀: Individual exemptions will no longer be possible to the extent they conflict with the CRD VI third-country rules.
- 𝗟𝗲𝗴𝗮𝗹 𝘂𝗻𝗰𝗲𝗿𝘁𝗮𝗶𝗻𝘁𝘆 𝗼𝗻 𝗲𝘅𝗲𝗺𝗽𝘁𝗶𝗼𝗻𝘀: Not all CRD VI exemptions have been expressly transposed in the BRUBEG – the government’s explanatory statement and any guidance at the European level (in particular by the European Banking Authority) will be important.
Should you have any questions regarding 𝗖𝗥𝗗 𝗩𝗜 𝗮𝗻𝗱 𝗕𝗥𝗨𝗕𝗘𝗚, or if you are interested in receiving the slides, please do not hesitate to get in touch.