Concerning the first threshold, we do not see any reason to refer to the volume of the Available for Sale portfolio (AfS). The AfS portfolio is a banking book portfolio which is widely used for asset/liability steering purposes. The volume of this portfolio is not a good indicator for the volume of proprietary trading. In page 101 of the Report it is clearly set out that these assets shall not be included in the ring-fence. Also the held for trading portfolio as such is not a good indicator as this portfolio covers not only proprietary trading. The needed volume.
