Dear Readers,

The near end of the summer break – at least in Hesse – gives reason for a brief outlook on the topics which will come up to VAB
members and the Association itself in the second half of 2018.

The progress of negotiations on UK’s withdrawal from the EU will be one of the most important issues for many members and  the Association. Of course much will depend on decisions at political level – forecasts are still difficult in this respect. Against this background, as already reported here on several occasions, numerous licensing procedures are underway and many  institutions concerned are discussing the expansion or the establishment of new entities with the supervisory authorities, but other preparations are also being made, such as, for example, the publication by the Federal Foreign Office of a transitional act which provides for the UK to continue to be treated as an EU member state at least for tax purposes, in case the  withdrawal agreement with a transition period by the end of 2020 is agreed on. In the near future, further laws will follow here, with the conclusion of the withdrawal agreement probably being the premise in each case. So much for Brexit.

EBA’s considerations for guidelines on outsourcing will also become largely relevant. They are still only available as draft and VAB will
also comment and take a position on this, especially as some of the ideas presented by EBA can only be realised with considerable effort by a large number of members. However, it is already foreseeable that the “MaRisk”, which was only amended at the end of last year, will have to be amended again in this chapter. VAB will advocate to ensure that the need for adaptation will be as low as possible and that the innovations will be manageable. The EBA guidelines on the disclosure of LCRs and the definition of groups of related customers have already been finalised. Even though BaFin is still consulting them, their application is foreseeable.

The implementation of PSD II still raises many questions; we report on this in the monthly information at various stages as well as on the topic of money laundering prevention, where further amendments are foreseeable. The overview could be continued at will.

It is foreseeable that the second half of 2018 will also bring many challenges both for our members and our office. In order to cope
with them, we have had welcomed a new colleague on 1 August. We report on this in the section “Internal Affairs”.

Kind regards
Dr. Oliver Wagner
Managing Director

Monthly Information V/2018