Association of Private Client Stockbrokers and Investment Managers
We strongly support the EBA’s proposal to adopt the subtractive approach. As the EBA has correctly identified, it can be used in cases where a firm does not use the International Financial Reporting Standards (IFRS) accounting framework and is, therefore, appropriate for a wider range of firms than an additive approach, including smaller or limited-authorisation investment firms who do not use the IFRS accounting framework. We support the EBA in its recognition of the need for RTS that take into account the differences in firms in terms of their size, structure or complexity.
We agree with the list of items.
Given that tied agents are to be included in the calculation of fixed overheads, we prefer that they are covered with a fixed lump sum per tied agent as proposed in the EBA’s consultation paper.
We agree with the proposed 20% threshold.
We do not consider it necessary to set a de minimis amount to exempt investment firms with capital requirements below this level from adjustments in capital requirements. We note, however, that Article 36a(5) does not appear to be laid out in the EBA’s consultation paper (EBA/CP/2013/30).
We agree with the introduction of the EUR 2 million absolute threshold.
On the assumption the existing proposals are adopted, we do not envisage that there will be material changes to the fixed overhead requirements for the vast majority of APCIMS member firms