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January 30 2019

DK comments on EBA’s Consultation Paper on Draft ITS amending Commission Implementing Regulation...

DK comments on the above-mentioned EBA consultation paper. The EBA changes the ITS requirements in both the credit risk and market risk areas. The exercise is relevant for institutions with IRB models or IMA models (market risk models) in Pillar I.

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August 31 2016

Comments on Notice 2016-42 (proposed changes to qualified intermediary agreements)

The new rules in section 5.03(B) of the proposed QI agreement provide that the LOB declaration (which may be used by entities that are not fiscally transparent to document their status together with “alternative” documentary evidence.

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July 15 2016

Dividend equivalent payments: Request to postpone the implementation date of Section 871(m)

We welcome the release on 1 July 2016 of Notice 2016-42 containing a revised proposed qualified intermediary agreement. Unfortunately, the notice fails to answer most of our open questions concerning the treatment by qualified derivatives dealers of...

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June 24 2016

Proportionality in the future market risk capital requirements and the review of the original...

On 26 May 2106, the European Commission published a consultation document on Proportionality in the future market risk capital requirements and the review of the original exposure method.

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