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ARTICLE · 10 NOVEMBER 2017

German Federal Financial Supervisory Authority (BaFin) Publishes Circular On Regulatory Requirements For Financial Institutions' IT Systems

Reed Smith (Worldwide)
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On 3 November 2017, the German regulator for the financial sector, the Federal Financial Supervisory Authority, published a new circular titled Rundschreiben 10/2017 (BA) vom 3. November 2017...

GermanyTechnology
Dr. Alexander Hardinghaus, LL.M.
Dr. Alexander Hardinghaus, LL.M.
Thomas Fischl
Thomas Fischl
Dr. Anselm Reinertshofer
Dr. Anselm Reinertshofer
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On 3 November 2017, the German regulator for the financial sector, the Federal Financial Supervisory Authority ("BaFin"), published a new circular titled Rundschreiben 10/2017 (BA) vom 3. November 2017 – Bankaufsichtliche Anforderungen an die IT (in English: Circular 10/2017 – Regulatory Requirements for IT-Systems – "BAIT"). The BAIT is available in German language at the BaFin's website. The final version of the BAIT incorporates a number of revisions that result from the submissions made by stakeholders in the course of a prior public consultation.

Scope of the BAIT

The BAIT's purpose is to give guidance on the BaFin's interpretation of the statutory requirements under Section 25a(1) s. 3 no. 4 and 5 and Section 25b of the German Banking Act (Kreditwirtschaftsgesetz – KWG). The BAIT sets out the BaFin's understanding of how reasonable technical/organisational features of IT systems used within financial institutions should look like, taking in particular

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