Response to eBA consults on technical standards on indirect subscription of MREL instruments within groups

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Q1. Do you have any views on the merits of the approach analysed by the EBA to implement the mandate or regarding other options considered under paragraph 14?

Please refer to the attached document

Q2. Could you describe the possible cases of daisy chains11 in the institutions you represent, taking into account the BRRD2 MREL conditions (but without considering waiver possibilities)?


Q3. In the institutions you represent, how would you deal with daisy chain situations? Do you plan to issue eligible liabilities directly from subsidiaries to the resolution entity, or rather indirectly through the intermediate subsidiaries?


Q4. The deduction regime increases in general12 the issuance needs of intermediate entities. What could be the financial impact(s) of such increase of issuances? (allocation of profits/distribution of dividends, capital of subsidiaries, buffers redistribution across the group, tax, etc.). Please answer qualitatively, and if possible, also quantitatively regarding the institution you represent.


Q5. In the institutions you represent, how many cases are there where an intermediate subsidiary is not regulated, or located in a non‐EU jurisdiction (and therefore not subject to banking capital requirements resp. MREL requirements), or where the CA has only set sub‐consolidated (and no individual) own funds requirements to an intermediate subsidiary (therefore no individual P2R or CBR applies to it)?


Q6. Are there any circumstances, including, but not limited to, the complexity of the Group, in which you would foresee significant issues with the implementation of this RTS? If so, please provide further details of the circumstances and the issues that would be faced.


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Name of the organization

ING Groep