The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the EBA amendments to the ITS on benchmarking of internal models.
We appreciate the fact that the EBA has decided to maintain an open dialogue with the industry on defining a suitable approach to integrate IFRS 9 models in the overall benchmarking exercise.
We would also encourage EBA to take full consideration of what it indicated in its roadmap for IFRS 9 deliverables (July 2019), i.e. that: “the process for a full benchmarking exercise is quite a lengthy one, taking generally 3 years, starting with the design of the template for data collection, taking in the integration of the exercise into the legal framework and ending with the publication of the horizontal report.”
In this respect, we would stress the need to avoid rushing in integrating IFRS 9 templates if there are still elements on which more refinement is needed.