We strongly support the EBA’s proposal to adopt the subtractive approach. As the EBA has correctly identified, it can be used in cases where a firm does not use the International Financial Reporting Standards (IFRS) accounting framework and is, therefore, appropriate for a wider range of firms than an additive approach, including smaller or limited-authorisation investment firms who do not use the IFRS accounting framework. We support the EBA in its recognition of the need for RTS that take into account the differences in firms in terms of their size, structure or complexity
Yes - should be a level playing field for all
Same manner as for investment firms - make it a level playing field.
yes - the amount should be calculated as a percentage of FOR
If the subtractive approach is taken then the changes are minimal to our type of firm but still ensure robust capital planning and requirements.