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Response to consultation on RTS on prudential requirements for central securities depositories (CSDs)
Go backQ2. Is the level of capital requirements as proposed in these draft RTS adequate to capture all the risks arising from the activities of a CSD? Are they proportionate for all the CSDs’ business models? Please justify your answer.
NAQ3. What are the operational or practical impediments to the implementation of the proposed methodology for the calculation of the capital surcharge (Article 9)? Do you envisage any amendment to the proposed methodology that might lead to a better measurement and management of those risks?
NAQ4. To what extent do CSD-banking service providers have the capability to have a real-time view on their positions with their cash correspondents, based on compulsory information provided by those cash correspondents (Article 14)?
NAQ5. What might be the practical, legal or operational impediments to the methodology set out in Sub-section on Collateral and other equivalent financial resources (Art. 18)?
NAQ6: What are the practical impediments of the implementation of Article 24?
NAQ7. To what extent do CSD-banking service providers hold their intraday liquidity risk buffers independently to other liquidity risk buffers, such as the Liquidity Coverage Ratio (LCR)? If this is not currently done, are there any obstacles to ensuring this? Can CSD-banking service providers estimate the intraday buffer assets required to meet Article 35 compared to the assets that they currently hold that would qualify as eligible liquid assets under this Regulation beyond the minimum LCR standard?
NAName of organisation
Association for Financial Markets in Europe - AFME
