QA2020-198 - Countercyclical buffer in MPEs

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Feb 01, 2024
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Resolution Reporting Subject Matter Guidance
Guidance Documents Reporting-on-MPE-banks
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QA2020-198

Question


Given that in MPEs the Resolution Group scope is smaller than the whole-group consolidated scope, wouldn’t it be more convenient to calculate a countercyclical buffer referred to the exact geographies where the credit activities of the Resolution Group is located? So far, it is being reported the countercyclical buffer assigned to the whole-group consolidated scope


Response


According to article 45c(4) of BRRD2 "EBA shall develop draft regulatory technical standards specifying the methodology to be used by resolution authorities to estimate the requirement referred to in Article 104a of Directive 2013/36/EU a+nd the combined buffer requirement for resolution entities at the resolution group consolidated level+ where the resolution group is not subject to those requirements under that Directive". Taking this into account we would suggest to continue with the current approach until the RTS is ready and the full CBR could be adjusted at the level of the Resolution Group.