Non-Financial Companies Aren't Shadow Banks

Deutsches Aktieninstitut is concerned that EBA is about to requalify all non-financial companies with centralised treasury or finance activities as shadow banks for regulatory purposes. This will be the outcome of a defintion that EBA proposes for the treatment of credit exposures of banks with the shadow banking sector. The main shortcome of the definition is that internal financial tranactions are not excluded. This position paper summarises Deutsches Aktieninstitut's concerns.