Response to consultation on draft regulatory technical standards on disclosure of information in relation to the compliance of institutions with the requirement for a countercyclical capital buffer

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Q02: Are the instructions provided in Annex 2 of the draft RTS sufficiently clear?

We suggest providing further instructions with regards to the distribution by geographical breakdown of columns 040-060.

Q03: Our analysis shows that the costs of implementation are negligible. Do you agree with our assessment? If not please explain why.

We agree with your assessment given that the institutions still have to carry out such calculations to determine the applicable ‘Institution specific countercyclical capital buffer requirement’.

Name of organisation

Malta Financial Services Authority