Submission #4

Primary tabs

View(active tab)

ICBC Europe

Question 1: Do you agree with the proposed clarifications with regard to the scope of consolidation? If in your view institutions belonging to third-country groups operating in the Union can have significant assets in third countries, please provide examples and, if possible, relevant values of assets. Yes

Question 2: Do you agree with the proposed clarification with regard to the calculation of the total value of assets in the Union for the purpose of the IPU threshold? Yes

Question 3: Do you agree with the proposed requirements for the exchange of information? Do you see any potential obstacles to exchanging the necessary information between the institutions and branches in the Union, which are part the same third-country group? Yes

Question 4: Do you agree with the clarifications regarding the timelines for establishing an intermediate EU parent undertaking? In your view, are there any other circumstances when establishing such undertaking may not be possible by the time the threshold of EUR 40 billion of the total value of assets is reached? Yes

Upload files Question to EBA.docx

Name of the organization ICBC Europe