Response to consultation on draft Regulatory Technical Standards on own funds requirements for investment firms based on fixed overheads

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Do you agree with the inclusion of tied agents, as set out in Article 36(4)? If not, what alternative do you suggest?

No comment.

you 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?

Given that tied agents are to be included in the calculation of fixed overheads, we prefer that they are covered with a fixed lump sum per tied agent as proposed in the EBA’s consultation paper.

Currently, a 35% share is proposed as the proportion of costs to be included for tied agents. Do you believe this is adequate?

No comment.

Do you agree with the proposed 20% threshold in Article 36a? Please provide evidence of the potential impact of this threshold.

We agree with the proposed 20% threshold.

Do 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?

We do not consider it necessary to set a de minimis amount to exempt investment firms with capital requirements below this level from adjustments in capital requirements. We note, however, that Article 36a(5) does not appear to be laid out in the EBA’s consultation paper (EBA/CP/2013/30).

Do you agree with the introduction of the EUR 2 million absolute threshold? If not, what should the amount be?

We agree with the introduction of the EUR 2 million absolute threshold.

Could 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?

On the assumption the existing proposals are adopted, we do not envisage that there will be material changes to the fixed overhead requirements for the vast majority of APCIMS member firms

Do 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?

No comment.

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Response to consultation on draft Regulatory Technical Standards on own funds requirements for investment firms based on fixed overheads

Do you agree with the inclusion of tied agents, as set out in Article 36(4)? If not, what alternative do you suggest?

you 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?

Currently, a 35% share is proposed as the proportion of costs to be included for tied agents. Do you believe this is adequate?

Do you agree with the proposed 20% threshold in Article 36a? Please provide evidence of the potential impact of this threshold.

Do 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?

Do you agree with the introduction of the EUR 2 million absolute threshold? If not, what should the amount be?

Could 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?

Do 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?

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