Response to consultation Paper on Draft Regulatory Technical Standards on the prudential treatment of software assets

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Question 1: In case some software assets are classified within tangible assets in your institution, what are the main reasonsfor doing so and what isthe percentage of this classification compared with the classification as intangible?

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Question 2: Do you have any comment on the proposed approach for the prudential treatment of software assets?

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Question 3: What is your view on the calibration of the prudential amortisation period?

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Question 4: What is your view on the proposed alternative approaches illustrated above?

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Question 5: If considered needed, please provide any complementary information regarding the costs and benefits from the application of these draft RTS.

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Question 6: If considered material, please provide your own estimate on the difference in the impact of prudential amortisation treatment between (i) assuming the capitalisation date of software assets as the starting point for prudential amortisation (ie. Option A illustrated in this CP) and (ii) assuming the date of accounting amortisation as the starting point for prudential amortisation, but fully deducting from CET1 items the costs capitalised until this date is (i.e. Option B illustrated in this CP) .

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Question 7: Please provide any additional comments on the Consultation Paper.

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Name of the organization

Association for Financial Markets in Europe (AFME)