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Associazione Bancaria Italiana

Question 1: Do you agree with this approach? Please explain how the application of the draft guidelines with the above amended scope would possibly affect current practices. Please specify what overall impact the extended scope would have. If relevant, please differentiate between the impact of considering connected clients due to control or connected clients due to economic dependencies.
Please, see the attached document
Question 2: Please explain how the application of the draft guidelines on connected clients would possibly change current practices regarding the categorisation of retail exposures? What is the likely impact of applying the draft guidelines on connected clients to the categorisation of clients in the retail exposure class (Article 123(c) and Article 147(5)(a)(ii) of the CRR)? If there is an impact, please provide concrete examples and both qualitative and quantitative information, specifying whether the impact is related to the Standardised Approach or the IRB Approach for credit risk.
Please, see the attached document
Question 3: Do you agree with the EBA’s assessment that there would be no impact of applying the draft guidelines on connected clients to development and application of the rating systems (Article 172(1)(d) of the CRR)?
Please, see the attached document
Question 4: Please explain how the application of the draft guidelines on connected clients would possibly change current practices regarding the use of the SME supporting factor? What is the likely impact of applying the draft guidelines on connected clients to the SME supporting factor (Article 501(2)(c) of the CRR)? If there is an impact, please provide concrete examples and both qualitative and quantitative information.
Please, see the attached document
Question 5: Please explain how the application of the draft guidelines on connected clients would possibly change current practices regarding the reporting to competent authorities, for instance in the area of liquidity? What is the likely impact of applying the draft guidelines on connected clients to reporting requirements, where relevant? If there is an impact, please provide concrete examples and both qualitative and quantitative information.
Please, see the attached document
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Pietro Scabellone