Response to consultation on draft RTS on the reclassification of investment firms as credit institutions

Go back

Q1: Is there any further element (including any potential simplification) concerning the accounting standards to be used for the purposes of these draft RTS that should be considered in this article?

In summary, the proposed approach not to allow for third-country GAAPs results in an unduly burdensome approach that would result in significant practical implications and costs.

Q2: This article is introduced to cover all possible cases envisaged in the definition of credit institution in point (1)(b) of paragraph 4(1) of the CRR (as amended by Article 62 of the IFR). Is there any other case that should be considered in clarifying the calculation methodology?

In summary, the calculation should not include the assets of non-EU subsidiaries of non-EU entities as there is no economical or risk rationale to do so.

Q3: Based on the provisions included in Articles 5, 6 and 7 of the draft RTS, do you anticipate any operational issues concerning the calculation of consolidated or combined assets? Please provide concrete examples.

In summary, the proposed approach results in an unduly burdensome approach that would result in significant practical implications and costs.

Upload files

Name of the organization

Jefferies