BaFin Issues Circular 11/2026 Consolidating Trustee Appointment Requirements for German Mortgage Ban
BaFin's Circular 11/2026 (BA), effective September 14, 2026, replaces the 2023 FAQs on trustee and deputy appointments under Sections 7 et seq. of the Pfandbrief Act (PfandBG). It sets out the eligibility criteria, the required documents and their validity periods, the fees, and the rules on remuneration and expenses. Mortgage banks should check their trustee renewal pipeline and internal processes against the new document and timing requirements.


