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Authors: Dr. Andreas Dehio, Roman Hoeck, Kathrin Hafner

FRQ - CRR III/CRD VI – Third country branches and impact on exemption orders

On 27 October 2021, the European Commission published three proposals amending the CRR, the CRD and the BRRD (the "Banking Package"). In the second issue of our series on the Banking Package, we are presenting the new rules on third country branches ("TCBs"), introduced by the proposal to amend the CRD, which also significantly impacts third country institutions holding national exemptions from licensing requirements, such as an exemption order (Freistellungsverfügung) under German law.