Draft Regulatory Technical Standards on the criteria to define managerial responsibility and control functions, material business unit and significant impact on their risk profile, and other categories of staff whose professional activities have a materia

21 February 2020

As outlined in the revised RTS for consultation as well as in the EBA Peer Review Report published in mid-January 2020, the RTS aim to end the current heterogeneity in the identification of risk takers within the EU by formulating clear and generally applicable criteria. However, the revised RTS for consultation coun-teract this objective. In fact, the new scope for interpretation would foster diverging implementation at a national level, rendering comparisons between individual companies increasingly difficult. In principle, we welcome the fact that the EBA has only selectively revised the catalogue of review criteria for the identification of risk takers (as per their brief), that is to say: the basic structure of the identifica-tion of risk takers remains unchanged. Accordingly, institutions are not faced with the challenge of devis-ing a fundamentally new review approach but can instead adapt existing review methods.

Cookie usage