The members of the EACB gladly take the opportunity to comment on the proposed EBA draft RTS on materiality threshold of credit obligation past due under Art. 178 CRR.
The paper rightly addresses the relevant factors and implications of setting a materiality threshold for the default definition. We particularly appreciate the analysis of both the current practice across the different Member States and of the implications and significant challenges for the institutions applying different approaches, especially the IRB approach. Bearing in mind the inherent complexity, we understand the challenge that the development this RTS represents for the EBA.
[Click on Download PDF]