Submission #3

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EACB - European Association of Co-operative Banks

Question 1: Do you agree with the three criteria developed in the Guidelines to assess a breach of the large exposure limits? Please refer to attached document

Question 2: Is there anything in particular that should be developed further in the guidelines to provide greater clarity on each of the three criteria? Please refer to attached document

Question 3: What are your views on the quantitative criteria included in paragraphs 16 and 17? Do you think that they can provide good guidance to competent authorities to assess a breach? Please refer to attached document

Question 4: In particular on the criterion “reasons beyond control of the institution”, do you think that the cases included in the guidelines reflect accurately current practices? Please refer to attached document

Question 5: Do you have any comments on the additional information that an institution should submit to the competent authority when a breach of the large exposure limits has occurred? Please refer to attached document

Question 6: Do you agree with the general principle that compliance with the large exposure limits should occur within one year? Please refer to attached document

Question 7: What cases could justify a period longer than one year to return to compliance? Please refer to attached document

Question 8: Paragraph 30 lists a number of elements that a competent authority should consider when deciding the specific time to return to compliance with the large exposure limits. Do you agree with them? Should the guidelines include further element/s? If your answer is yes, please elaborate. Please refer to attached document

Question 9: Do you agree with the main content of the compliance plan as set out in paragraph 40 in order to ensure return to compliance or are some measures missing? Alternatively, do you think that some of the measures would not be necessary? Please elaborate further in either case. Please refer to attached document

Question 10: Should the guidelines benefit from including further procedural details? Please refer to attached document

Upload files EACB comments EBA draft GL on LE breaches_20210517.pdf

Name of the organization EACB - European Association of Co-operative Banks