Response to consultation on draft RTS on the identification of a group of connected clients (GCC)
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We agree that it’s preferable to maintain the previous mention "significant" rather than to set a threshold of 50% of ownership. This leaves room for analysis/interpretation in specific cases and is consistent with the notion of connected clients, which emphasizes an expert analysis.
Question 6. In point (c) of Article 2(1), would you prefer following a quantitative approach by replacing the term “significant part” with a threshold of “50% or more” as envisaged in point 1 of LEX 10.16? What would be the advantages or disadvantages? Please elaborate.
We agree that it’s preferable to maintain the previous mention "significant" rather than to set a threshold of 50% of ownership. This leaves room for analysis/interpretation in specific cases and is consistent with the notion of connected clients, which emphasizes an expert analysis.
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EBA-CP-2022-07 - GCC.pdf
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