Response to consultation on draft technical standards on own funds - Part IV

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Is the application of the different tests clear? How do you assess the approach retained for non-joint stock companies?

See attached EACB position paper

How do you assess the applicability of the conditions in paragraph 2?

See attached EACB position paper

Is the chosen approach applicable to all instruments that may be issued by non-joint stock institutions?

See attached EACB position paper

How do you assess the proposed levels of 30% for the payout ratio in paragraph 5(d) of Article 7b?

See attached EACB position paper

Is the application of the different tests clear? How do you assess the approach retained for non-joint stock companies?

See attached EACB position paper

Name of organisation

European Association of Co-operative Banks - EACB