BBA response to CEBS draft guidelines on AMA changes (CP 45)
The BBA supports the principal objective of CP 45 to clarify banks' approval processes for AMA changes and the necessary communication with and, where appropriate, approval by bank regulators.
We have concerns regarding two principal areas of the consultation paper:
- Home-host issues – specifically not fully taking into account the circumstance where an EU bank which has a non-EU parent has an approved AMA model; and
- Overly complex categorisation of types of AMA changes and (as currently defined) the requirement to have too many types of changes pre-approved/communicated in advance.
Please read the full response via the link below.