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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 - should be a level playing field for allyou 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?
Same manner as for investment firms - make it a level playing field.Currently, a 35% share is proposed as the proportion of costs to be included for tied agents. Do you believe this is adequate?
No viewDo you agree with the proposed 20% threshold in Article 36a? Please provide evidence of the potential impact of this threshold.
No viewDo 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?
yes - the amount should be calculated as a percentage of FORDo you agree with the introduction of the EUR 2 million absolute threshold? If not, what should the amount be?
No viewCould 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?
If the subtractive approach is taken then the changes are minimal to our type of firm but still ensure robust capital planning and requirements.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 viewName of organisation
Murray Asset Management Limited
