Response to consultation on guidelines for common procedures and methodologies for the supervisory review and evaluation process (SREP)

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Q2. Do you agree with the proportionate approach to the application of the SREP to different categories of institutions? (Title 2)


Q3. Are there other drivers of business model / strategy success and failure that you believe competent authorities should consider when conducting the BMA? (Title 4)

The 3 line sof defence model should be considered

Q4. Does the breakdown of risk categories and sub-categories proposed provide appropriate coverage and scope for conducting supervisory risk assessments? (Title 6)


Q5. Do you agree with the use of a standard approach for the articulation of additional own funds requirements to be used by compete authorities across the Union? (Title 7)


Q6. Do you agree that competent authorities should be granted additional transition periods for meeting certain capital and liquidity provisions in the guidelines (Title 12)?


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Name of organisation

European Confederation of Institutes of Internal Auditing (ECIIA)