EBA is consulting on RTS under article 77 of the fourth Capital Requirements Directive (CRD4) setting out at what point a national regulator should encourage a financial institution to develop internal models for calculating the level of capital needs arising from debt instruments in the institution's trading book. EBA proposes to set the trigger at the level where the sum of all long and short positions surpass EUR 1 billion, and where the institution's portfolio includes more than 100 positions in debt securities and each is greater than EUR 2.5 million. It asks for comments by 15 October. (Source: EBA Consults on RTS Related to the Specific Risk of Debt in the Trading Book)