- Question ID
-
2024_7043
- Legal act
- Regulation (EU) No 2019/2033 (IFR)
- Topic
- K-factor requirements
- Article
-
21
- Paragraph
-
(4)
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
-
n/a
- Type of submitter
-
Investment firm
- Subject matter
-
Net position risk - K-NPR
- Question
-
We understand that rTM measures are for firms that deal on their own account. The relevant K-Factor for position risk, K-NPR falls under rTM, therefore the assumption would be that K-NPR refers only to firms dealing on their own account. However, Article 21(4) sets out that for purpose of calculating the rTM K-factor requirement, firms should also include positions other than trading book positions where it gives rise to foreign exchange or commodity risk.
Does then Article 21(4) bring firms that do not deal on their own account into the scope of K-NPR or is it an additional requirement only for firms that deal on their own account?
- Background on the question
-
It is being proposed by local regulators that indeed Article 21(4) is designed to capture fx and commodity risk exposures within a firm that sit outside the definition of ‘dealing on own account’
- Submission date
- Status
-
Question under review
- Answer prepared by
-
Answer prepared by the European Commission because it is a matter of interpretation of Union law.