Submission #12

Primary tabs

View(active tab)

European Association of Public Banks (EAPB)

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

Question 2: Point (d) has been added, throughout the Guidelines references to money laundering and terrorism financing and the institutions obligations have been added, are those references sufficiently clear? N/A

Question 3: Paragraph 24 regarding ESG factors has been added, is it sufficiently clear? N/A

Question 4: Paragraph 84 and 86 have been amended to reflect changes to CRD. Are those paragraphs sufficiently clear? N/A

Question 5: Are Paragraphs 98 and 99 sufficiently clear? N/A

Question 6: Point (c) of paragraph 101 has been amended to reflect the EBA’s work on dividend arbitrage schemes. Is point (c) sufficiently clear? N/A

Question 7: Section 11 has been added to provide guidelines on loans and transactions with members of the management body and their related parties, reflecting changes to CRD. Is the section appropriate and sufficiently clear?

EAPB considers that it would be helpful if the term “other transactions” in section 11 (“Loans and other transactions with members of the management body and their related parties”) could be defined more precisely. We wonder whether securities transactions also fall under this term.

Question 8: Paragraph 126 has been added, is it sufficiently clear? N/A

Question 9: Paragraph 140 has been added, is it sufficiently clear? N/A

Upload files

Contact name Farid Aliyev