Response to consultation on Technical Standards on structural foreign exchange under CRR
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Q1. Do you agree with the clarification provided in Article 1 of these proposed RTS?
Please find the full EBF response to this CP in the attached document.
Q2. Do you agree with the criteria to identify the significant currencies for an institution? Do you agree with a threshold set at 1% or do you deem that a higher threshold (e.g. 2%) would create more level playing field across institutions If not, what would be alternative criteria? Please elaborate.
Please find the full EBF response to this CP in the attached document.
Q3. Do you agree that internal trades cannot be considered as taken for hedging the ratio? Please elaborate.
Please find the full EBF response to this CP in the attached document.
Q4. What do you think should be cases of positions potentially exempted under the provisions included in Article 5(c)? Please elaborate.
Please find the full EBF response to this CP in the attached document.
Q5. Do you agree with the simplification allowing institutions to use only credit risk RWA in the determination of the MAX_OP? Please elaborate.
Please find the full EBF response to this CP in the attached document.
Q6. Do you expect that institutions currently using the derogation referred to in Article 6(4) would qualify for the treatment referred to in paragraph 3 of that Article? Please elaborate.
Please find the full EBF response to this CP in the attached document.
Q7. Do you agree with the requirements set out in Article 7(1)(j), and in Article 7(3)? Do you see the need to introduce additional safeguards to address, for example, currency crisis? Please elaborate.
Please find the full EBF response to this CP in the attached document.
Q8. Did you identify any issues regarding the representation of the RTS policy framework for S-FX in the ITS reporting requirement?
Please find the full EBF response to this CP in the attached document.
Q9. Are the scope of application of the reporting requirements, the template itself and instruc-tions clear?
Please find the full EBF response to this CP in the attached document.
Q10. Does the reporting of the net reduction in own funds requirements (c0130) by currency, or any other element of the reporting requirement, trigger a particularly high, or in your view dis-proportionate, effort or cost of compliance? If yes, please explain the trigger/source of the cost and offer suggestions on alternative ways to achieve the same/a similar result with lower cost of compliance.
Please find the full EBF response to this CP in the attached document.