Submission #12

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European Association of Co-operative Banks - EACB

How do you assess the suggested limits of 125% under Article 7b (1)(a) and 105% under Article 7b(1)(b) for joint stock companies (or non-joint stock companies, where applicable)? See attached EACB position paper

How do you assess the proposal to disqualify all dividend multiple instruments when the 105% limit is breached, for joint stock companies or non-joint stock companies, where applicable? In which circumstances would this limit not work or be breached without the institution being able to prevent this breach? 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

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

File Upload 140107_EACB position paper on EBA draft RTS on Own Funds IV_final.pdf

Name of organisation European Association of Co-operative Banks - EACB