Submission #20

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FIA

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?

Please see FIA clearing members' feedback on the proposed draft K-CMG RTS in the attached pdf response. Thank you for consideration of our comments. We would be happy to discuss them in more detail with the EBA.

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

Upload files FIA response to EBA consultation on IFR draft K-CMG RTS - final version.pdf

Name of the organization FIA