The paper outlines the rationale behind the treatment of structural positions as well as broader issues related to the structural FX concept, such as the actual nature of FX risk, considering both the accounting and regulatory perspectives.
It also examines in greater detail the potential inconsistencies in the articulation of the FX requirements, both in the current Capital Requirements Regulation (CRR) as well as in the CRR2 proposal for institutions applying the standardised and internal model approaches.
The application of this provision can have a significant effect on capital requirements and is currently subject to various interpretations that have led to differences in its application, both in EU Member States and across banks. This raises potential concerns about the level playing field, as it could lead to significant differences in capital requirements across institutions with similar exposures. The EBA is, therefore, of the view that a more harmonised application and enforcement of this provision is necessary and intends to produce own initiative guidelines on this topic.
With this Discussion Paper the European Banking Authority (EBA) is seeking feedback at an early stage in the process on stakeholders' current practices and interpretations of the structural FX provision.
Comments to this consultation can be sent to the EBA by 22 September 2017. A public hearing will take place at the EBA premises on 25 July from 14 to 16 UK time.
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Discussion paper
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