The German Banking Industry Committee (Deutsche Kreditwirtschaft – DK) has published a position paper regarding the Second Financial Markets Amendment Act (Zweites Finanzmarktnovellierungsgesetz – 2. FiMaNoG). The German Banking Industry Committee (GBIC) is the voice of the leading German banking-sector associations, consisting of the National Association of German Cooperative Banks (BVR), the Association of German Banks (BdB), the Association of German Public Banks (VÖB), the German Savings Banks Association (DSGV), and the Association of German Pfandbrief Banks (vdp).
The DK paper focuses on proposed amendments to the Securities Trading Act (Wertpapierhandelsgesetz – WpHG). The DK position paper can be found here. Additionally, a short description of the DK’s comments on the 2. FiMaNoG can be found here in German.