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The German Banking Industry Committee (GBIC) has issued its comments to the public consultation of the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) - EBA/GL/2020/19 - on the revision of joint guidelines for assessing the suitability of members of the management body and key function holders under Directive 2013/36/EU and Directive 2014/65/EU. In addition to numerous proposals to adapt the guidelines to the practice of the institutes, GBIC generally criticizes that the present consultation paper, like the previous guidelines, goes beyond the requirements of the CRD.