EBF response to the BCBS Consultative document:
Regulatory treatment of accounting provisions –
interim approach and transitional arrangements

Key points:

• The transition period should not be introducing any phasing before there is clarity on how the prudential framework will be amended long-term.
• For jurisdictions applying IFRS 9, the transition regime should apply from 2018. In the period from 1 January 2018 to 31 December 2019 a bank should include in CET 1 capital an adjustment amount of 100 % (coefficient 1).
•  Should the final framework be in place by 2020, the phasing as envisaged by the Basel Committee could then be adopted which would make more sense given that the phasing-in would take place on the basis of a real impact.
• As for the approach to the calculation of the transitional adjustment amount, the EBF supports alternative 3 given its dynamic approach and conceptual relevance.