Response to consultation on draft RTS on the identification of a group of connected clients (GCC)

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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.

A more precise definition of "significant part" by a threshold would facilitate classification.

Question 7. What is your view on the wording “that cannot be replaced in a timely manner without excessively increased costs” compared to the wording used in the GL “that cannot be easily replaced”? What do you think about this change, is it more comprehensible? Please elaborate.

The new wording leads to the need to calculate and quantify the associated costs. The cost factor associated with the replacement of a failed business partner is not always clearly quantifiable, other non-monetary factors can complicate this search. This change will therefore lead to incalculable effort.

Name of the organization

Lloyds Bank GmbH