Response to consultation on draft ITS amending Commission Implementing Regulation (EU) 2024/3117 regarding Credit Risk and IFRS 9 Benchmarking reporting
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General 1: Are the instructions and templates clear to the respondents? If not, what should be clarified?
Are default cases for IRB retail exposures that exceed the maximum IRB recovery period considered out of scope of the new C104.00 ITS Benchmark exercise (loss rates template)?