Response to consultation on Guidelines on limits on exposures to shadow banking

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6. Taking into account, in particular, the fact that the 25% limit is consistent with the currentlimit in the large exposures framework, do you agree it is an adequate limit for the fallback approach? If not, why? What would the impact of such a limit be in the case of Option 1? And in the case of Option 2?

We consider the 25% limit, applied to a widely defined and very heterogeneous sector, is conservative.
Then, in addition to the main distinction based on the prudential framework, we consider that the following criteria could be used to introduce granularity in the treatment of shadow banking entities:
- the nature of the activities/business (consumer credit or financial leasing cannot reasonably be treated the same way as money market funds);
- the existence, nature and level of risks (systemic risk in particular) ;
- the possibility of “run” effects (sudden and massive withdrawals of funds by clients).

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ASSOCIATION FRANCAISE DES SOCIETES FINANCIERES