Comment letter to EBA benchmarking due to Article 78 CRD IV
The European Banking Authority (EBA) has published the draft of the revised Implementation Standard (ITS) for the annual benchmarking exercise according to Art. 78 CRD IV in December 2019. The main change relates to the introduction of the benchmarking templates according to IFRS 9. Initially, only data on low default portfolios (LDP) with a focus on the probability of default (PD) will be collected.