Submission #4

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BNP Paribas Bank Advisory Team, Corporate & Institutional Banking division

Question 1: In case some software assets are classified within tangible assets in your institution, what are the main reasonsfor doing so and what isthe percentage of this classification compared with the classification as intangible? N/A

Question 2: Do you have any comment on the proposed approach for the prudential treatment of software assets? Yes, see enclosed document

Question 3: What is your view on the calibration of the prudential amortisation period? As a pragmatic, workable compromise, 5-years would be much better than 2-years

Question 4: What is your view on the proposed alternative approaches illustrated above?

Of the alternatives presented, prudential amortisation makes the most sense. It would have been nice at least to have appraised the option of full non-deduction

Question 5: If considered needed, please provide any complementary information regarding the costs and benefits from the application of these draft RTS. N/A

Question 6: If considered material, please provide your own estimate on the difference in the impact of prudential amortisation treatment between (i) assuming the capitalisation date of software assets as the starting point for prudential amortisation (ie. Option A illustrated in this CP) and (ii) assuming the date of accounting amortisation as the starting point for prudential amortisation, but fully deducting from CET1 items the costs capitalised until this date is (i.e. Option B illustrated in this CP) .

We cannot share data on this topic, nor do we express any “preference”. Our preferred option would be for software WIP to be fully capitalised and not deducted, with amortisation to commence upon delivery and extend for the full economic life of the operating software asset. However, we do not believe the EBA is considering this option at present.

Question 7: Please provide any additional comments on the Consultation Paper. Please see enclosed document

Upload files 200703 BNPP Bank Advisory re regulatory deduction of software CRR changes EBA feedback.pdf

Name of the organization BNP Paribas Bank Advisory Team, Corporate & Institutional Banking division