Submission #13

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EU Federation for Factoring and Commercial Finance - EUF

Question 1: Do you agree with the conditions of Article 1 paragraph 2 for identifying an entity as a non-shadow banking entity? Please provide reasons if you do not agree with any of the conditions or have comments with regard to any of them. Kindly refer to the EUF response uploaded separately.

Question 2: Have you got any comments regarding the list of entities that, being exempted or optionally excluded from those four legal acts in Annex I, should not be considered as shadow banking entities? Kindly refer to the EUF response uploaded separately.

Question 3: Conversely, what are your views concerning other entities exempted or optionally excluded from the other legal acts in Annex I and that would be identified as shadow banking entities? Please provide reasons in case you view that any of those entities should fall under the exemption in Article 1 paragraph 3 and therefore not be treated as shadow banking entities. Kindly refer to the EUF response uploaded separately.

Question 11: Do you agree with the possibility granted under paragraph 1 of Article 3 to prevent the identification of a bank in a third country as a shadow banking entity in the absence of an equivalence decision under Article 391 of the CRR? Kindly refer to the EUF response uploaded separately.

Question 13: Do you agree with the list of legal acts included in Annex I? Kindly refer to the EUF response uploaded separately.

Question 14: Is there any other legal act that should be included in Annex I? If yes, please mention the act and legal reference, and provide reasons to support it based on the criteria included in Article 394(4) of Regulation (EU) No 575/2013. Kindly refer to the EUF response uploaded separately.

Upload files EUF response to EBA consultation draft RTS identification of shadow banking entities 20211026.pdf

Name of the organization EU Federation for Factoring and Commercial Finance - EUF