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The inputs gathered from stakeholders will assist the EBA in the development of draft regulatory standards (RTS) on how these prudent valuation requirements should be applied. These RTS will also cover the analysis of the costs and benefits that the legal requirements will imply.
Articles 31 and 100 of the fifth Council compromise version text from 11 May 2012 of the draft Capital Requirements Regulation (CRR) require institutions to apply prudent valuation standards to all positions that are measured at fair value when calculating the amount of their own funds. Any additional value adjustments necessary to reduce the fair value of those positions to the relevant prudent value, as calculated in accordance with the relevant accounting standards, should be deducted from common equity tier 1 capital.
The draft CRR mandates the EBA with the task of developing RTS to provide more details on how the standards set out in Article 100 should be applied. In particular, Article 100 lays out a number of valuation adjustments that should be considered when calculating a prudent valuation. The intended effect of these adjustments is to set valuations at a level that achieves an appropriate degree of certainty that the valuation used for regulatory purposes is not higher than the true realisable value. With this aim in mind, this paper considers the possibility of defining what the ‘appropriate degree of certainty’ or level of confidence is that the requirements wish to achieve in the adjusted valuation.
The EBA invites comments on the issues raised in this discussion paper by 13 January, 2013.