German Banking Industry Committee

At present the Draft ITS does not contain suggestions for concrete thresholds. For example, with re-gard to Annex X (“Interconnectedness”), it remains unclear from which “threshold” on interconnect-edness should be disclosed. In our view there is clearly a need to render more precisely when a par-ticular criterion is considered to be significant enough to justify disclosure, as to ensure a “level play-ing field”.
NA
German Banking Industry Committee