Response to consultation on draft revised Guidelines on recovery plans indicators

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Question 1: Do you have any comments on the general requirements that should drive the calibration of recovery indicators as proposed in paragraph 27 of these guidelines?

Please refer to attached document.

Question 2: Do you have any comments on the requirement that there should be no automatic recalibration of recovery indicators upon the application of temporary supervisory relief measures, however it could be allowed by competent authorities in those cases specified in paragraph 31 of these guidelines?

Please refer to attached document.

Question 3: Do you have any comments on guidance introduced in relation to actions and notifications upon breaching recovery indicators, including the proposed timelines for internal escalation and notification to the competent authorities?

Please refer to attached document.

Question 4: Do you have any comments on introducing a possibility for competent authorities to request institutions to provide a full set of recovery indicators (breached or not)?

Please refer to attached document.

Question 5: Do you have any comments on the proposed threshold calibration of regulatory capital indicators at levels above those requiring supervisory intervention and therefore to be generally calibrated above the combined capital buffer requirement while still allowing calibration within buffers only under certain conditions?

Please refer to attached document.

Question 6: Do you have any comments on the proposed calibration of the recovery threshold for MREL?

Please refer to attached document.

Question 7: Do you have any comments on the proposed threshold calibration of regulatory liquidity indicators (LCR and NSFR) above their minimum regulatory requirement i.e. 100%?

Please refer to attached document.

Question 8: Do you have any comments on the proposed threshold calibration for the indicator of liquidity position?

Please refer to attached document.

Question 9: Do you have any comments on the proposed changes to the minimum list of recovery plan indicators?

Please refer to attached document.

Question 10: Do you have any comments on the impact assessment?

Please refer to attached document.

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Name of the organization

European Association of Co-operative Banks (EACB)