Response to consultation Paper on draft ITS amending the benchmarking Regulation
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assumption for years ahead:
• IMV reference date: “5 working days after the booking date”
• RM final reference date: “10 working days after the RM initial reference date”
Q4: Stakeholders are invited to express their view on the new reference date specification with respect the precedent method to specify the reference dates for the exercise.
We feel the IMV reference date and RM final reference date and similarly defined reference dates are ambiguous, as the definition implies that everyone uses the same business calendar – which, even if holds true for the two mentioned reference dates in 2020-2021, might be a strongassumption for years ahead:
• IMV reference date: “5 working days after the booking date”
• RM final reference date: “10 working days after the RM initial reference date”