In the feedback table that follows, the EBA has summarised the comments received and explains which responses have and have not led to changes, and the reasons for this.
As part of the general comments several respondents claimed that only positions leading to gains or losses that are accounted for in the P&L should be capitalised. The EBA would like to note that Article 352(1) does not link in any way the accounting treatment with a possible exclusion from the FX capital charge. Positions of type A are accordingly attracting own funds requirements for FX risk. Not capitalising them would make an institution non-compliant with the CRR text. As a result, no changes have been made to reflect this comment.
With respect to the scope of the applications of the waiver, all respondents were against any potential restriction requiring institutions to hedge the CET1 ratio. Some respondents were in favour of requiring all institutions to use the standardised approach for performing the calcu
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