Submission #5

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European Association of Co-operative Banks (EACB)

Question 1: How could the guidelines be further simplified in a way that appropriate focus of assessment is allowed while preserving the comprehensiveness of the assessment and ensuring that all aspects are sufficiently covered? Please refer to attached document.

Question 2: Do you think that the proposed overall framework for setting additional own funds requirements appropriately incorporates the ICAAP information and estimates? Please refer to attached document.

Question 3: Do you agree with the proposed clarifications on the assessment of the risk of excessive leverage? Please refer to attached document.

Question 4: Do you think that the assessment of dimensions and indicators described in this explanatory box would also be relevant for the assessment of the risk of excessive leverage? Are there any other elements / indicators that you are using in the assessment of this risk? Please refer to attached document.

Question 5: Can you provide examples of situations which in your view might require CET1 instead of other capital instruments to cover potential losses in relation to P2R and P2R-LR? Please refer to attached document.

Question 6: Would you consider the introduction of a standardised template for the communication to the supervised institution of the outcome of the SREP to be beneficial? Please refer to attached document.

Question 7: What are your views on the guidance for setting P2G and P2G-LR? Is it sufficiently clear? Please refer to attached document.

Question 8: What are your views on possible disclosures, which may be attached to P2G and/or ranges of buckets in case they are identified? Please refer to attached document.

Question 9: What are your views on the capital instruments potentially used to cover losses in relation to P2G-LR? Please provide the rationale or specific examples for your views. Please refer to attached document.

Upload files EACB comments draft revision EBA SREP GL_fin_20210927.pdf

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