Response to consultation on the benchmark rate under the Mortgage Credit Directive

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Question 1: Do you agree with the EBA’s approach to deliver the EBA benchmark rate by publishing a formula from which creditors can calculate the rate? If not, outline why you disagree and suggest an alternative approach including the reasons for the suggestion.

Yes, EACB members support the EBA’s approach to deliver the EBA benchmark rate by publishing a formula, instead of a rate.

Question 2: Do you agree with the proposed EBA formula? If not, outline why you disagree and specify how the formula could be improved.

Yes, EACB members agree with the proposed EBA formula.

Question 3: Do you agree with the underlying rate to be input into the proposed EBA formula If not, outline why you disagree and suggest alternative rate, including the reasons for the suggestion.

Yes. EACB members agree with the underlying rate to be input into the proposed EBA formula.

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EACB response to EBA consultation on the EBA proposed benchmark rate under Annex II of the MCD.pdf (341.72 KB)

Name of organisation

European Association of Co-operative Banks