EBA has published a discussion paper, open for comments until 13 January, setting out its preliminary views on the TS due under article 100 of CRR. This article says fair value positions must be subject to standards of prudent valuation, and deductions from common equity tier 1 capital be made accordingly. This prudent valuation needs to achieve certainty having regard to the dynamic nature of trading book positions. The discussion raises the question of what degree of certainty as to the swings in assets value the adjusted valuation should offer. It also discusses how to arrive at aggregate prudent values. (Source: EBA Discussion Paper on TS on Prudent Valuation)