Response to consultation on Guidelines for common procedures and methodologies for SREP

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Question 1: What are the respondents’ views on the overall amendments and clarifications added to the revised guidelines?

The amendments provide a better understanding of the overall requirements especially with regard to P2G, however, I would like to make reference to section 5.7.1 Risk Appetite framework and Strategy. It is still not clear what constitutes an 'ideal' Risk Appetite Framework and Risk Management Framework. There is reference to risk limits, tolerances, and thresholds, however, there is no clear definition which is required to ensure harmonisation across the banking industry.

Name of organisation

MDB Group