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FEFSI and EAMA strongly believe that Member States should not have the option to limit the use of the EBR approach and a reduction in the current proposed calibration factors would be justified for investment firms that are part of a larger group using the Basic Indicator Approach or the Standardised Approach not to experience a significant increase in their capital requirements at the consolidated level.
Furthermore, all investment firms that decide to use the Standardised Approach should be exempted from the requirement to comply with the EBR. An appropriate income definition for investment firms is required taking into account the specificities of the income sources of investment management companies.
Finally, insurance should be recognised as a risk mitigant for operational risk across all methodologies and the treatment of investment funds in banking books should be improved to allow institutions to use different approaches to calculate a capital requirement reflecting the true risk associated with holding an investment fund.