In its opinion the EBA sets out both general and specific comments on the changes proposed by the Commission. This includes that the EBA considers the proposed changes to be of a substantive nature, covering the notion of a large decline to Article 6 of the draft RTS submitted. The EBA also considers that these amendments alter the draft technical standards in a significant manner from a technical perspective. Furthermore, the EBA has concerns that the proposed changes would create an undue burden to Member State competent authorities.
In response to the Commission’s proposed amendments the opinion contains an annex in which the EBA has revised the substantive amendments to Recital 4 and Article 6 of the draft RTS it submitted.
Finally, given recent events, which are also related to interest rate risk in the banking book (IRRBB) aspects, the EBA stresses the importance to adopt, without delay, the draft RTS which are a crucial piece of the EU regulatory framework for the harmonised assessment and monitoring of exposures of EU institutions to IRRBB.
