We believe that the provisions included in these draft RTS are sufficiently clear. We do however suggest to include a further column in table 1 of Annex I to multiply column 080 by column 090. The aggregate summation of the latter multiplication (row 020) is required to calculate the ‘Institution specific countercyclical capital buffer rate’ (row 020 of table 2).
We suggest providing further instructions with regards to the distribution by geographical breakdown of columns 040-060.
We agree with your assessment given that the institutions still have to carry out such calculations to determine the applicable ‘Institution specific countercyclical capital buffer requirement’.