Response to eBA and ESMA launch consultation to revise joint guidelines for assessing the suitability of members of the management body and key function holders

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Question 1: Are subject matter, scope of application, definitions and date of application appropriate and sufficiently clear?

Please refer to the attached document.

Question 2: Are the changes made in Title II appropriate and sufficiently clear?

Please refer to the attached document.

Question 3: Are the changes made in Title III appropriate and sufficiently clear?

Please refer to the attached document.

Question 4: Are the requirements in section 12 sufficiently clear; are there additional measures that should be required to ensure that diversity is appropriately taken into account by institutions and that the principle of equal opportunities for all genders is appropriately reflected?

Please refer to the attached document.

Question 5: Are the changes made in Title VI appropriate and sufficiently clear?

Please refer to the attached document.

Question 6: Are the changes made in Title VII appropriate and sufficiently clear?

Please refer to the attached document.

Question 7: Are the changes made in Title VIII appropriate and sufficiently clear?

Please refer to the attached document.

Question 8: Are the changes made in Title IX appropriate and sufficiently clear?

Please refer to the attached document.

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Name of the organization

European Association of Co-operative Banks (EACB)