Response to consultation on Guidelines on specification of types of exposures to be associated with high risk

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Question 1: Do you agree with the proposed clarifications in paragraphs 2 and 3? Would you like to bring forward arguments which potentially mitigate the caveats of the alternative approach for defining what constitutes an investment in private equity?

We do not agree with the proposal since other exposures different from the one already listed in CRR Article 128(2) and in paragraphs 5a and 5b of the EBA CP already represents clear segments that can be affected by a high risk of loss. For the remaining perimeters, considering that it will be very improbable, as also recognized by EBA, that other exposures (such as Corporate, Retail) can be classified as high risk, we deem more appropriate to concentrate and require investigation on perimeter where the risk of high loss is more likely, avoiding a burden of activities on process and classification sides for the Banks on those segments where the frequency of being a high risk exposure is very unlikely.

Question 2: Do you agree that the identification of high risk items is particularly relevant for some of the existing exposure classes?


Question 3: Do you have any comments or concerns regarding the proposed scope of the exposures at least to be analysed according to paragraph 5? Should more guidance be provided as regards other types of exposures? If yes, please provide specifications.


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