Response to joint Consultation on the Guidelines on the convergence of supervisory practices relating to the consistency of supervisory coordination arrangements for financial conglomerates

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3. Do you consider appropriate the minimum number of meetings described in paragraphs 49 and 50?

Lessons learned from the supervision of financial conglomerates so far clearly indicate that a regular exchange of experiences among supervisory authorities involved improve the understanding of the risk situation the conglomerate is operating under. This will help supervisors to focus their efforts and resources on issues which are material for the purpose of supplementary supervision. We are afraid that a minimum cycle of yearly meetings is not sufficient to materialize the benefits from face-to-face encounters. The ESAs may want to consider semi-annual meetings as an assumption.

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Name of organisation

German Insurance Association (GDV)