Comments related to Annex I Disclosure of information relevant for the calculation of the countercyclical buffer
1. Since the countercyclical is intended to constrain excessive credit growth, it is our understanding that the countercyclical buffer percentages per country are to be weighted with credit risk RWAs (column 040) or with credit risk exposures (column 010). We do not understand the need to include all RWAs (or exposures) in columns 020, 030, 050, 060 or 070 as they are not related to excessive credit growth. Since the columns will not materially change the final bank-specific countercyclical buffer percentage the countercyclical buffer percentage we propose to delete them from the table.
2. We note that article 440 of the CRR also speaks of “credit exposures” and not of other risk types.
3. It is not clarified in the RTS how to allocate operational risk RWAs to specific countries, for instance RWAs assigned to system risk of an IT system, built in country A, used in countries B, C and D, to serve clients in countries B, C, D, E and F.
4. Even if the EBA would provide a mechanism for such an allocation, we think that it would trigger excessive additional work for both banks following these guidelines and regulators questioning this, certainly compared to the added value – if any – of such exercise.
5. We note that also for market risk an allocation to specific countries may not be straightforward.