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?

We understand that a granular information should be provided for the consolidated basis and a summarized breakdown for the relevant subsidiaries. Only if necessary, more granular information could be disclosed for relevant subsidiaries regarding counterparties (LRSpl).

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.

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

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?

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.

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