Response to consultation on draft ITS on Pillar 3 disclosure

Question 1: Are the amended/new templates EU OV1, EU KM1, EU CMS1, EU CMS2 and the related instructions clear to the respondents? If no, please motivate your response.

As no special space is foreseen for an introductory comment / a general comment, we are using this space in order to do so.

In the attached paper, we propose a new disclosure item with regard to the nomination of ECAIs for the purpose of calculating the output floor. Additionally, we call on institutions to review their existing ECAI nominations under the Standardized Approach as our research has shown that some institutions still include references to National Competent Authoroties (and in some rare cases to the ECB).

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