BaFin Issues Circulars on Refinancing Register Administrators and Mortgage Bank Trustees
BaFin has published Circulars 10/2026 (BA) and 11/2026 (BA), setting out its administrative practice and expectations for appointing refinancing register administrators under the KWG and trustees under the PfandBG, including their deputies. Institutions must demonstrate that candidates are independent, reliable, and sufficiently expert. Compliance teams at covered institutions should review their appointment files and processes against these expectations.


