Submission #13

British Bankers' Association

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)? BBA has no comments.

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? BBA has no comments.

Is the application of the different tests clear? How do you assess the approach retained for non-joint stock companies? BBA has no comments.

How do you assess the applicability of the conditions in paragraph 2? BBA has no comments.

Is the chosen approach applicable to all instruments that may be issued by non-joint stock institutions? BBA has no comments.

How do you assess the proposed levels of 30% for the payout ratio in paragraph 5(d) of Article 7b? BBA has no comments.

Is the application of the different tests clear? How do you assess the approach retained for non-joint stock companies? BBA has no comments.

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Name of organisation British Bankers' Association