Submission #6

AFME

General comments Please see uploaded file

Is a trigger event of no less than 7 % of the CET 1 appropriate for AT1 instruments to ensure that the instrument reflects appropriately credit quality as a going concern? Please see uploaded file

Would it be preferable for the trigger events for different instruments to be based uniformly on a CET1 ratio? Please see uploaded file

What would be an appropriate differentiation with regard to the percentages set for a trigger event based on CET1 ratios for Additional Tier 1, Tier 2 and other instruments? Should there be a unique trigger level for all classes of instruments? Please see uploaded file

Is the cap on distributions in Article 1 (2) (a) set at an appropriate level? Please see uploaded file

Is the definition of the cap appropriate or should another rate be used as a basis for calculating the cap? Please see uploaded file

What are the additional costs of ensuring that instruments meet the criterion in Article 1 (2)(b) (60 % issued to other investors)? Please see uploaded file

Are the trigger events for Tier 2 instruments based on the Tier 1 capital ratio appropriately defined and easy to apply? Please see uploaded file

Are the percentages set for the trigger events appropriate? Please see uploaded file

Is the write-down and write-up mechanism for Tier 2 instruments easy to apply? Please see uploaded file

Are there other write-down mechanisms which would be better suited for instruments used for the purpose of variable remuneration? Please see uploaded file

Is it appropriate to include instruments linked to Additional Tier 1 and Tier 2 instruments in the class of other instruments? Please see uploaded file

Are the requirements set for linked instruments appropriate? Please see uploaded file

Is it appropriate to allow for conversion of other instruments? Please see uploaded file

Is is appropriate to require a permanent write-down for other instruments? Please see uploaded file

Are the trigger events for other instruments appropriately defined and easy to apply? Please see uploaded file

Are the percentages set for the trigger event appropriate? Please see uploaded file

Are the specified conditions appropriate? Should additional conditions be considered? Please see uploaded file

Is the conversion and write-down mechanism for other instruments sufficiently clear and easy to apply? Please see uploaded file

Are the above requirements regarding conversion sufficiently clear and easy to apply? Please see uploaded file

Do you agree with our analysis of the impact of the proposals in this consultation paper? Please see uploaded file

Can you provide any evidence or data that may further inform our analysis of the likely impacts of the proposals? Is there any relevant impact of the draft RTS on other areas which the EBA has not considered? Please see uploaded file

Do the draft RTS lead to any impediments regarding the issuance of own funds instruments? Please see uploaded file

Upload files AFME submission on EBA instruments RTS - 29 Oct 2013.pdf

Name of organisation AFME