Response to consultation on ITS on MREL reporting by Resolution Authorities

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Question 1: Do you consider that any of the components of the ITS Templates presented in the Annex I and Annex II to inform the EBA of the mínimum requirement for own funds and eligible liabilities are not appropriate, and if so why?

We understand the reporting of the leverage ratio denominator as a potential backstop calibration for MREL in-line with TLAC.

Question 2: Do you consider that any additional components are needed to be included in the templates presented in Annex I and Annex II, and if so why?


Question 3: Do you consider it necessary to split the line 190 of the Annex 1 ‘downward adjustment taking into account information received from the competent authority relating to the institution's business model, funding model, and overall risk profile’ into invidual lines for each component i) business model, ii) funding model, and iii) overall risk profile?

No, as we would expect to report more granular data according to these components to the NRA.
Furthermore we would suggest to include a justification, if no such adjustment is made.

Question 4: Do you consider it necessary to add additional lines to gather information on MREL subordination requirements? If yes, how granular information is needed?

We prefer a harmonization which refers to the principles of the French approach.

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Name of organisation

Austrian Federal Economic Chamber