The EACB welcomes the opportunity to comment on the EBA’s draft revised Guidelines on limits on exposures to shadow banking entities. We believe that ensuring stability, maintaining coherence within the prudential framework, and avoiding new definitions is the right approach to simplify the framework and reduce the burden on banking institutions.
In our feedback, we call for the reintroduction of a materiality threshold for exposures to shadow banking entities, ensuring consistency between the Guidelines and the Delegated Regulation (EU) 2023/2779. Without such alignment, institutions would still need to review all exposures under the Regulation.
We also request further clarification on how to interpret certain borderline situations, notably for entities whose activities are only partly related to shadow banking and institutions from third countries subject to equivalent regulatory frameworks.
Finally, we warn that hard limits on exposures to shadow banking entities could limit the lending capacity of affected institutions within the EU and shift lending to countries outside the Union.