The EACB welcomes the possibility to comment on the EBA draft revised Guidelines on limits on exposures to shadow banking entities which carry out banking activities outside a regulated framework under Article 395(2) and (2a) of Regulation (EU) No 575/2013.
In our response, we support the approach implemented by the EBA in reviewing these Guidelines. We believe that it upholds the stability of the framework, while ensuring coherence of the prudential framework and avoiding establishing new definitions is the right approach to ensure the simplification of the framework and reduce the burden of banking institutions.
We remarked the importance of reestablishing a materiality threshold to recognise an exposure to individual shadow banking entities. The threshold should also be taken into account in the Delegated Regulation (EU) 2023/2779. Otherwise, institutions will benefit from a simplification under the Guideline but will be required to review all exposures under the Delegated Regulation.