Submission #3

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Association for Financial Markets in Europe

The EBA is interested in collecting views on whether the baseline scenario is appropriate and balanced between the need to recognize the European Banking Union integration process and the strong desire to apply and fully adhere to Basel international standards. Should respondents be more towardsfavouring options a), b) or c), kindly comment on whether the proposed range(s) is either i) appropriate, ii) too wide, or iii) too narrow. Answers to question and options laid described above are most welcome when considering the need and intention of the EBA to stay as closely aligned with the international standards as possible.

Please refer to file attached.

AFME has put in place internal arrangements to manage our work in compliance with the conditions set by the EBA on Adam Farkas’ appointment as CEO. As part of these, Adam Farkas has not been involved in the preparation of this consultation response.

Considering the above, the EBA welcomes views on whether the different FX conversion methods should be taken into account and clearly disclosed when designing the EU additional methodology to assign G‐SII buffer rates. For instance, the average bank‐specific impact across the alternative FX conversion methods could be taken and applied as a second step of the EU additional methodology, with the view of reaching a final EU revised G‐SII score. Additional context about this question and related options is provided in the impact assessment section of this consultation paper. Please refer to file attached.

Do the respondents agree that the proposed implementation of the disclosure required in Article 441 of the CRR fits the purpose of the underlying regulation? Please refer to file attached.

Upload files EBA Consultation - G-SIIs Methodology - August 2020.pdf

Name of the organization Association for Financial Markets in Europe