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European Savings and Retail Banking Group

EBA is currently developing several concepts related to IRB in addition to the recently published consultation from BIS (which introduces capital floors). ESBG is therefore concerned of possible divergent approaches appearing from those different regulations/standards and also from different calendars for implementation. This potential lack of synchronisation concerning the publication of different regula-tions/criteria/standards - currently either in-force or in-study - will impact financial institutions which will have to recalculate the same position under different standards. Finally, we understand that since no concrete proposal has been presented yet, the quantitative impact in terms of capital requirements is quite uncertain and impossible to quantify.
• The DP suggests a future calendar for Regulatory Technical standards (RTS) and Guidelines that shall be published in the coming years. The timetable for publication and implementation seems ambitious (EBA has delayed it already in its recently updated 2015 work programme).
César Blanco