Response to consultation on draft Implementing Technical Standards (ITS) on disclosure for leverage ratio

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Are the instructions provided in annex 2 on the breakdown of leverage ratio exposure of LRCom and LRSpl sufficiently clear? Should the instructions for some rows be clarified? Which ones in particular? Are some rows missing?

The proposals are clear but as we explained in Q1 we think these provisions are too granular, therefore we don’t support them.

Our analysis shows that no impacts incremental to those included in the text of the Level 1 text are likely to materialise. Do you agree with our assessment? If not please explain why and provide estimates of such impacts whenever possible.

If any disclosure will mainly be based on our reporting data, we agree with the fact that there will be no massive additional costs for setting up this new requirement. In the contrary we do not agree with your conclusion that no significant impacts will be induced.

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Name of organisation

French Banking Federation