Article 14 says that to calculate concentrated positions AVA there is a three-step approach. After a concentrated valuation position is identified, when a market price is available for the size of the valuation position, a prudent exit period shall be estimated. If the prudent exit period exceeds 10 days, AVA shall be estimated as explained in Article 14.1(c). Clarification is needed to confirm what is the final amount concentrated position AVA shall be estimated on.

Article 14.1(c) rules that AVA should be estimated when it takes more than 10 days to be free of the position, taking into account average daily volume, the typical daily trading volume of the institution, and a cap to daily trading volume to avoid an impact on the market price of the position. In our opinion, this guideline also implies that, taking into account the same mentioned volume restrictions, if an institution hypothetical exit strategy on that position takes 10 days or less therefore there is no need for concentrated position AVA calculation. In the sight of this, we would like to clarify if concentrated position AVA should be therefore estimated for the volume that would be part of a hypothetical exit strategy going from the eleventh day, to the number of days of the prudent exit period.