The EACB welcomes the opportunity to comment on the EBA Draft RTS on the on the allocation of off-balance sheet items and Unconditional Cancellable Commitments (UCC). The right allocation of the off-balance sheet items to the appropriate buckets of conversion factors is crucial for a number of transactions of high relevance for customers across Europe, both for retail and SMEs/corporate clients.
To this end, we believe that the EBA should further clarify some of the policy proposals, better reflect the substance of certain contractual arrangements, and reconsider some of the stated factors seen as potentially constraining the institutions’ ability to cancel UCCs.