Consultation Paper Regarding Large Exposure Limits
SIFMA AMG has submitted comments on the proposed guidelines of the European Banking Authority (“EBA”) on the scope of the term “group of connected clients” for purposes of the large exposure limits of Regulation (EU) No 575/2013 (the “Regulation”).
SIFMA AMG understands and shares the goal of the Regulation’s large exposure limits: reducing the risks to a bank arising from the failure of one or more significant clients. We further understand that, in this context, it is critical to identify accurately the types of bank clients that are so economically related to each other that they should be considered a “group of connected clients” under the Regulation. As discussed in further detail in SIFMA AMG’s letter, we believe that certain aspects of the Proposed Guidelines are overbroad in explaining the circumstances in which multiple clients are connected to each other such that they form a “single risk.” In their conservatism, the Proposed Guidelines would have unintended negative consequences for banks’ asset management clients, particularly clients based outside of Europe.
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