We were among the signatories of a short submission to the European Commission coordinated by the EMF-ECBC regarding the use and interpretation of the new “property value” concept in the Capital Requirements Regulation framework. The letter can be seen here.
By way of background: this is the same thing as the “prudent value” or “prudently conservative valuation criteria” concept in the Basel 3 finalisation measures discussed (ad nauseam, frankly) in past newsletters, mostly in relation to the UK’s proposed implementation (see for example here). The position taken in the letter is on all fours with our own past representations (and the conclusions of work on long-term value methodologies further to the 2014 Vision report).
