Submission #13

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European Association of Co-operative Banks (EACB)

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? Please see attached document.

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

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

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

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

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) . Please see attached document.

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

Upload files Final_EACB comments EBA draft RTS prudential treatment software.pdf

Name of the organization European Association of Co-operative Banks (EACB)