The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the draft EBA RTS on the prudential treatment of software assets under Article 36 CRR as amending Delegated Regulation (EU) 241/2014 (RTS own funds).
In fact, European banks continue to be at a disadvantage compared to other jurisdictions and industries. Being able to adequately accompany increased digitization of the banking industry is and will be a key element for financial stability. This will also be relevant to sustain and improve profitability.
We appreciate that the EBA is seeking to design an approach that is as simple as possible and close to the accounting perspective. At the same time we believe that certain aspects of the calibration of the amortization mechanism should be improved.
We would also recommend that, in light with the recently adopted CRR quick fix package, as a response to the effects of the COVID 19 pandemic, the adoption of the RTS can be as expedite as possible. However, in order to take into account possible delays a (potentially) retrospective application of the requirements as of September 30, 2020 could be envisaged.