Submission #12

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Association for Financial Markets in Europe (AFME)

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? See attached.

Question 2: Do you have any comment on the proposed approach for the prudential treatment of software assets? See attached.

Question 3: What is your view on the calibration of the prudential amortisation period? See attached.

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

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

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) . See attached.

Question 7: Please provide any additional comments on the Consultation Paper. See attached.

Upload files AFME Response (July 2020) to EBA consultation on Draft RTS on the prudential treatment of software assets.pdf

Name of the organization Association for Financial Markets in Europe (AFME)