Submission #3

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Association of Russian Banks

Question 1: Can you think of any additional indicators that should be included in Table 1 of Annex 1, or indicators that are better suited to reflect systemic relevance? Please provide evidence supporting your view where possible.

We suggest the off-balance sheet items to be included in Table 1 of Annex 1. From Table 1 of Annex 1 (page 19) there is not obvious within absolute measures for D-SIB whether off-balance sheet items (absolute or risk-weighted) should be used together with balance sheet size and total assets (absolute or risk-weighted) in MS.

Question 2: Do you agree that there may be Member States where small institutions are unlikely to pose systemic threats to the domestic economy? Do you think the option to exclude these institutions could reduce the administrative burden for institutions, or do you think there is a risk that the results of the analysis could be distorted by excluding them?

In our point of view, the answer depends on concentration in Member States.If concentration in Member States is low, small institutions matter; otherwise – not.

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Name of organisation Association of Russian Banks