Response to consultation on methodology for global systemically important institutions

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(Question relating to the draft RTS) Are the timelines for the identification process and the coming into force of the buffer requirement adequate, and do they allow for sufficient time for adjusting to it?

We request to synchronize the disclosure of the indicators by the banks and the list of global systematically important institutions (G-SII), in order to avoid confusion for investors and analysts (i.e November).
Due to a lack of precision in the ITS, we are in favour of the public disclosure of the indicators only.

(Question relating to the draft Guidelines) Are the template and the instructions clear and sufficiently comprehensive for enabling institutions to complete the disclosure process?

The template provided by the EBA should be completed with cross references in the Excel spreadsheet, related to other reporting templates and a “memo” from the supervisor should be drafted to provide the same guidelines to all banks (i.e. the classification of economic agents). This way, the process would be more robust, as an auditable process should be.

(Question relating to the impact assessment) 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 would explain why you disagree or might further inform our analysis of the likely impacts of the proposals?

no comment

Name of organisation

French Banking Federation