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Response to consultation on draft Regulatory Technical Standards on own funds requirements for investment firms based on fixed overheads
Go backDo you agree with the inclusion of tied agents, as set out in Article 36(4)? If not, what alternative do you suggest?
yes, we agree with your Authorityyou agree that the inclusion of tied agents would be covered with a certain amount related to a tied agent rather than a variable sum? Or do you prefer the capital requirement to be calculated in the same manner as for the investment firm?
Yes, we agree with the Authority that the inclusion of tied agents should be covered by a percentage related to a tied agent.Currently, a 35% share is proposed as the proportion of costs to be included for tied agents. Do you believe this is adequate?
We believe that the percentage should be increased to at least 40%, as a natural consequence of the evolution of remuneration of tied agents in the near future, both for the regulated application of CRD3 by the authorities, and because of national contractual discipline of the professional category.Do you agree with the proposed 20% threshold in Article 36a? Please provide evidence of the potential impact of this threshold.
Non-ApplicableDo you consider it necessary to set a de minimis amount for small investment firms, as set out in Article 36a(5)? If yes, what should the amount be?
Non-ApplicableDo you agree with the introduction of the EUR 2 million absolute threshold? If not, what should the amount be?
Non-ApplicableCould you provide any evidence (qualitative or quantitative) or data that would help the EBA to estimate more precisely the potential change in the own funds requirement in your jurisdiction?
Non-ApplicableDo you agree with our analysis of the impact of the proposals in this CP? If not, can you provide any evidence or data that might further inform our analysis of the likely impacts of the proposals?
Non-ApplicableName of organisation
ANASF - ASSOCIAZIONE NAZIONALE PROMOTORI FINANZIARI
