Response to consultation on draft Implementing Technical Standards (ITS) on disclosure for leverage ratio
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As the comments we would like to make raise issues which are not covered by those questions, we attach our positioning and urge the EBA to take them into account.
As the comments we would like to make raise issues which are not covered by those questions, we attach our positioning and urge the EBA to take them into account.
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 do not consider the various questions which are being raised in the consultation paper to be particularly relevant as they do not reflect the main concerns we have.As the comments we would like to make raise issues which are not covered by those questions, we attach our positioning and urge the EBA to take them into account.
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.
We do not consider the various questions which are being raised in the consultation paper to be particularly relevant as they do not reflect the main concerns we have.As the comments we would like to make raise issues which are not covered by those questions, we attach our positioning and urge the EBA to take them into account.