Submission #8

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Deutsche Börse Group

Is the proposed articulation of the K-factors calculation methods, in particular between AUM and CMH and ASA, exhaustive or should any other element be considered? Non-Applicable

Are the requirements for notion of segregated accounts sufficient? Are there issues on segregated accounts which need to be elaborated further? Non-Applicable

Is there any example of situations of market stress which would not been taken into account applying the proposed approach but would be relevant for the measurement of the K-DTF?

Please see the attached Deutsche Börse Group position paper in this regard, which also contains further comments on the consultation paper in general.

What would be appropriate thresholds or events that should trigger the comparison between the calculation under the K-CMG compared to the one under the K-NPR? Non-Applicable

Which other conditions should be considered to avoid double counting or to prevent regulatory arbitrage in the use of the K-CMG approach?

Please see the attached Deutsche Börse Group position paper in this regard, which also contains further comments on the consultation paper in general.

Do you have any comment on the elements included in this Consultation Paper for the application of the aggregation method? Non-Applicable

Do you currently use the method of proportional consolidation for the consolidation of subsidiaries in accordance with Article 18(4) of Regulation (EU) No 575/2013? If proportional consolidation is used, please explain if the conditions included in this Consultation Paper are met. Non-Applicable

Do you have any comments on the conditions established in this Consultation Paper to apply proportional consolidation to investment firms groups under Regulation (EU) No 2019/2033? Non-Applicable

The methods for calculating the K-factors in a consolidated situation may allow for further specifications. Is there any K-factor for which the calculation in the context of the consolidated basis would require further specifications? What aspects should be considered? Non-Applicable

Upload files 20200904 DBG response to EBA RTS on IFR-IFD.pdf

Name of the organization Deutsche Börse Group