The EACB welcomes the opportunity to comment on the Draft Delegated Act amending Regulation (EU) No 575/2013. The proposal introduces temporary and targeted relief measures, as well as specific multipliers, for the calculation of institutions' own funds requirements for market risk.
We acknowledge the FRTB as a significant improvement over the previous Market Risk Standard, introducing more risk-sensitive methodologies and strengthening the prudential treatment of trading activities. However, the transition to the FRTB may increase capital requirements, notably through a significant rise in risk-weighted assets (RWAs) and could undermine the competitiveness of EU banks.
The EACB stresses the need for a legally certain and transparent transition towards a permanent framework, providing institutions with sufficient planning certainty and avoiding disruptive capital and competitive impacts once the transitional measures expire. The EACB also sees the forthcoming EU Commission Report on the Competitiveness of the EU Banking Sector as an opportunity to provide further clarity on these issues.