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Version date: 18 March 2022 - onwards

4.9 Identification of key vulnerabilities (paras. 95-96)

95. Having conducted the BMA, competent authorities should assess the key vulnerabilities to which the institution's business model and strategy expose it or may expose it, considering any of the following:

a. poor expected financial performance;

b. reliance on an unrealistic strategy;

c. excessive concentrations or volatility (e.g. of revenues, earnings, customers subject to enhanced customer due diligence set out in Chapter II, Section 3 of Directive 2015/849, high-risk third countries in accordance with Article 9 of that Directive, deposits and assets under custody/management related to such high-risk third countries;

d. excessive risk-taking;

e. funding structure concerns;

f. significant external issues (e.g. regulatory threats, such as mandating of 'ring-fencing' of business units); and

g. ESG risks and their impact on the viability and sustainability of the business model and long-term resilience of the institution.

96. Following the above assessment, competent authorities should

Comparing proposed amendment...