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Association of Foreign Banks in Germany

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Regarding Title IV, section 9, paragraph 99 of the Guidelines

We would propose amending the newly inserted paragraph 99 as follows:

“Credit institutions policies should be gender neutral and credit institutions should implement measures that ensure equal opportunities for all genders, including with regard to career perspectives and to improve the representation of the underrepresented gender in management positions. In this respect, the proportionality principle should be considered, i.e. an exception should apply to institutions with a management body of less than four members."

Reasons:
In principle, we welcome the stipulation that the management positions of an institution should be gender equitable. In our view, the size of the management body as well as the group aspect should be included in the consideration of gender equality.

Example:
In case of a small subsidiary with a two- or three-member management body, the gender of the management body alone should not be considered, because the group of people concerned is too small in order to achieve meaningful diversity.
Regarding Title IV, section 9, point (c.) of paragraph 101 of the Guidelines

We would propose adding a footnote with the definition of the term “dividend arbitrage schemes”.

Reasons:
From our point of view, the user should have a clear understanding of what EBA means by the term "dividend arbitrage schemes". Therefore, we would propose adding a footnote with the definition of the term “dividend arbitrage schemes”.
Regarding Title IV, section 11 of the Guidelines

We would propose adding a description of types of loans and other transactions.

Reasons:
A provision on loans and other transactions with members of the management body and their related parties should indicate which different types of loans should be covered. In this respect, a description of types of loans could be inserted in a paragraph or in a footnote.
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Association of Foreign Banks in Germany