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ARTICLE · 09 JANUARY 2026

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Regulatory Monitoring - December 2025

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BaFin announced that it has launched a new survey on cum/cum transactions, following surveys in 2017, 2020 and 2021.

GermanyFinance and Banking

1. Bank regulation

1.1 PRUDENTIAL REGULATION

a) General

(i) Germany

BaFin: Renewed survey of German credit and securities institutions on cum/cum transactions (Erneute Abfrage deutscher Kredit- und Wertpapierinstitute zu Cum/Cum-Geschäften)

Status: Final

BaFin announced that it has launched a new survey on cum/cum transactions, following surveys in 2017, 2020 and 2021. The survey is aimed at the majority of German credit institutions, selected investment institutions and institutions in the field of financial market infrastructures, all external capital management companies with a licence that manage open-ended securities funds, as well as insurance companies and pension funds under federal supervision. The purpose of the new survey is to obtain an up-to-date overview of the financial burdens on the companies surveyed and to examine the need for supervisory action. This is important as participation in cum/cum transactions is not only of supervisory

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