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EBIC highlights that there are a number of practical problems in respect of accounting and proposes to reconcile the definition of minimum lease payments given in IFRS. National discretions contained in the proposed Directive need to be analysed thoroughly to achieve greater convergence.
EBIC also seeks clarity on the calculation of the operational risk capital charge and calls for thorough consideration at EU level of the definition of the boundary between the Trading and Banking Books, following the Basel / IOSCO Joint Trading Book Review.
Finally, EBIC notes that there is no mention in the proposed Directive of which national supervisor is responsible for exercising specific national discretions. For many options the allocation of regulatory competencies is not clear at all. Therefore, EBIC proposes that each national discretion be definitively attributed to the appropriate supervisor.