Response to consultation on Guidelines on ESG scenario analysis
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Question 1: Do you have any comments on the interplay between these Guidelines and the Guidelines on the management of ESG risks?
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Question 2: Do you have comments on the proposed definition of scenario analysis and its various uses as presented in Figure 1?
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Question 3: Do you have comments on the proposed distinction made between short-term scenario analysis (CST) and longer-term scenario analysis (CRA) as illustrated in Figure 3?
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Question 4: Do you have any comments on the interplay between these Guidelines and the Guidelines on institution’s stress testing?
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Question 5: Do you have comments on the Climate Scenario Analysis framework as illustrated in Figure 4?
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Question 6: While respecting the definitions provided in other parts of the regulation, is there any concept/s used in these guidelines that it would be useful to include in an annexed glossary?
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Question 7: Do you have comments on section 4.1 Purpose and governance?
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Question 8: Do you agree that the proposed proportionality approach is commensurate with both the maturity of the topic and the size, nature and complexity of the institution’ s activities?
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Question 9: Do you agree with the proposed references to organisations in paragraph 28? Would you suggest alternative or complementary references?
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Question 10: Do you have additional comments on section 5.1 Setting climate scenarios?
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Question 11: Do you have comments on the description of the climate transmission channels?
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Question 12: Do you have comments on climate stress test (CST) tool and its use to test an institution’s financial resilience?
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Question 13: Do you have comments on the Climate Resilience Analysis (CRA) tool and its use to challenge an institution’s business model resilience?
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Question 14: Do you have any additional comments on the draft Guidelines on ESG Scenario Analysis?
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