The EBA has written to Commissioner Barnier in relation to some serious concerns raised by various stakeholders with respect to some of the proposals under consideration in the definition of own funds. The EBA suggests that the co-legislators should strengthen the provisions currently included in Recital 53 of the CRR in order to ensure that only common equity instruments are included in the capital of the highest quality for joint-stock companies, in particular in cases where they have significant international activities.

The EBA has also written to Commissioner Barnier in relation to some observations of serious discrepancies in the application of transitional floors to capital requirements. The EBA considers that a consistent methodology for the calculation of the floor should be based on the standardised approach in force, and not on an older set of regulations and therefore should rely on the standardised approach as defined in the CRR rather than on risk weighted assets calculated according to the Basel 1 framework.