Responses to questions in Consultation Paper EBA/CP /2024/22

Question 1. What is the percentage of exposures

within your retail portfolio that are part of a group of connected clients?	Only two associations provide data.	-	Amendments to
Comments Summary	of responses received	EBA analysis	the proposals

Question 2. Do you identify

any implementation issue in implementing the diversification method?	Most associations highlighted that the proposed diversification method is particularly burdensome.	Refer to the EBA analysis in the ‘ General Comment ’ section.
Question 3. Which methods do you currently use to assess retail diversification? Please elaborate.	The majority of medium-large banks use the 0.2% criterion, a quantitative measure, while small banks, in particular, mainly use qualitative criteria. The qualitative criteria were not further specified.	Refer to the EBA analysis in the ‘ General Comment ’ section.

Question 4. Under the proposed approach, in the first step of the calculation before any exclusion, what is the share in terms of

Only four institutions provide data.

exposure value of the large eligible retail exposures as defined under the proposed approach compared to all the eligible retail exposures?

Question 5. What is the impact of the proposed	It was highlighted that the proposed diversification tests could disproportionately		Amendments to
Comments Summary	of responses received	EBA analysis	the proposals
diversification assessment set out in these Guidelines	penalise smaller banks, increasing their capital requirements and potentially reducing their ability to offer credit.
compared to the diversification assessment that you currently perform	Only three institutions provide supporting data.

on your retail portfolio?

1. Ħarsa ġenerali

Titlu	Regolamentazzjoni

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