EBF: EBA consultation on systemic risk buffers: EBF response

30 July 2020

The EBF has responded to the consultation paper of the European Banking Authority (EBA) on draft Guidelines on the appropriate subsets of sectoral exposures to which competent or designated authorities may apply a systemic risk buffer in accordance with the Capital Requirements Directive.

Key concerns of the EBF members are related to a high degree of complexity of the proposal, the need to ensure consistency in the implementation of the framework, and the need to keep the operational burden for banks low. Therefore, the EBF calls on the EBA to consider the following key concerns:

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