Response to consultation on draft RTS on the reclassification of investment firms as credit institutions
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Q1: Is there any further element (including any potential simplification) concerning the accounting standards to be used for the purposes of these draft RTS that should be considered in this article?
N/A See full response attachedQ2: This article is introduced to cover all possible cases envisaged in the definition of credit institution in point (1)(b) of paragraph 4(1) of the CRR (as amended by Article 62 of the IFR). Is there any other case that should be considered in clarifying the calculation methodology?
N/A See full response attachedQ3: Based on the provisions included in Articles 5, 6 and 7 of the draft RTS, do you anticipate any operational issues concerning the calculation of consolidated or combined assets? Please provide concrete examples.
N/A See full response attachedUpload files
BPFI IFR RTS Response.pdf
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