YES. Both alternative proposals appears to be quite complex to implement.
We prefer Option 2. The reason is in that the application of the threshold both at the consolidated and at the individual level is unduly burdensome for a large group with many subsidiaries. Moreover, it is somewhat contradictory, especially in case of Article 150 (1) (c), because banking groups often allocate marginal business units or segments to dedicated subsidiaries (e.g. for the purpose of subsequent asset disposal), which would inevitably breach the threshold at the individual level. Finally, it would be awkward if an asset class or a segment under permanent use of SA at the consolidated level, were material at the individual level, thus obliging a subsidiary to develop a model on a stand-alone basis. Option 1 mitigates but do not address fully these drawbacks of the proposed approach.