The EACB welcomes the opportunity to comment on the Basel Committee’s Revised assessment framework for G-SIBs.
We agree with the stated aim to address window-dressing activity and ensure that banks are allocated the appropriate “significance” bucket. We also appreciate the extensive accompanying documentation published by the Committee.
However, we believe that some of the proposed revisions would reveal disproportionate and overly costly for banks that participate in the assessment exercise, particularly those that would clearly not qualify as a G-SIB.
We also recommend some refinements concerning high-frequency averaging requirements.