The EBA has developed these own-initiative draft guidelines on the practical implementation of ‘structural FX’ provision contemplated in Article 352(2) of the CRR.
Article 16(2) of Regulation (EU) No 1093/2010 (EBA Regulation) provides that any guidelines and recommendations developed by the EBA should be accompanied by an analysis of ‘the potential related costs and benefits’. This analysis should provide an overview of the findings regarding the problem to be dealt with, the solutions proposed and the potential impact of these options.
This section presents the cost-benefit analysis of the main policy options included in the draft guidelines. Given that there are no specific reporting requirements related to structural FX in the current supervisory reporting framework (COREP/FINREP), the analysis is high level and qualitative in nature.
A. Problem identification
Article 352(2) of the CRR allows competent authorities to permit, on an ad hoc basis, the exclusion of FX risk posi
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