Circle submitted a short response to EIOPA's consultation on capital requirements for investments in crypto-assets in the EU 🇪🇺 EIOPA’s current draft advice proposes a uniform 100% stress factor on all crypto-assets, a method that overlooks the varying risk profiles of different asset classes. A meme token should not have the same risk weight as a fully HQLA backed e-money token issued by a regulated financial institution. This has been recognised by the EU Capital Requirements Regulation (CRR) transitional measures for crypto. The CRR incorporates a look-through approach for EMTs, a methodology that ensures proportionality and that MiCA authorized EMTs can be adopted by financial institutions in the insurance sector. The CRR also distinguishes further between ARTs and unbacked crypto-assets (see screenshot below). We believe EIOPA's advice should be aligned with the CRR transitional measures for crypto. Therefore, we oppose their draft proposition of a uniform 100% to all types of crypto-assets. @circle supports Policy Option 4, which emphasizes a nuanced approach to crypto-assets depending on the risk profile as established by the CRR.