Response to consultation on Regulatory Technical Standards on detailed records of financial contracts

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2. If the answer is no. What alternative trigger could be used?

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3. Do you agree with the list of information set out in the Annex to the draft RTS which it is proposed shall be required to be maintained in the detailed records?

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4. If the answer is no. What alternative approach could be used to define the circumstances in which the requirement should be imposed in order to ensure proportionality relative to the aim pursued?

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5. Do you agree that in the Annex to the draft RTS the same structure as in Commission’s delegated regulation (EU) no 148/2013 should be kept?

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6. Considering the question above do you think it would be possible and helpful to define expressly in the RTS which data points should be collected at a “per trade” level, and which should be collected at a “per counterparty” level?

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Name of organisation

EBA Banking Stakeholder Group