Comments on revised EBA Guidelines on the management of IRRBB
The German Banking Industry Committee (GBIC) appreciates the opportunity to comment on the Draft Guidelines on the management of interest rate risk arising from non-trading book activities published on 31 October 2017 (EBA/CP/2017/19). The GBIC is highly critical of this revision. According to the GBIC, in particular the following points are not acceptable:
Regarding the content of the Guidelines, the EBA has exceeded its mandate. Moreover, many of the required calculations are not relevant for management purposes and proportionality is not reflected adequately. In its comments on the Draft guidelines, the GBIC illustrates these central points of criticism and replies to the questions on the Draft Guidelines posed by the European Banking Authority (EBA).