Submission #8

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EACB - European Association of Co-operative Banks

Question 1: Do you have any general comments on the draft Guidelines on methods for calculating contributions to DGSs? See attached document

Question 2: Do you consider the level of detail of these draft Guidelines to be appropriate? See attached document

Question 3: Is the proposed formula for calculating contributions to DGS sufficiently clear and transparent? See attached document

Question 4: Considering the need for sufficient risk differentiation and consistency across the EU, do you agree on the minimum risk interval (75%-150%) proposed in these Guidelines? See attached document

Question 5: Do you agree with the core risk indicators proposed in these Guidelines? If not, please specify your reasons and suggest alternative indicators that can be applied to institutions in all Member States. Do you foresee any unintended consequences that could stem from the suggested indicators? See attached document

Question 6: Do you agree with the option to use either capital coverage ratio or Common Equity Tier 1 ratio as a measure of capital? Would you favour one of these indicators rather than the other, and why? See attached document

Question 7: Are there any particular types of institutions for which the core risk indicators specified in these Guidelines are not available due to the legal characteristics or supervisory regime of these institutions? Please describe the reasons why these core indicators are not available. See attached document

Question 8: Do you think that more guidance, or specific thresholds, should be provided in these Guidelines with regard to calibration of buckets for risk indicators, or minimum and maximum values for a sliding scale approach? See attached document

Question 9: Do you agree with our analysis of the impact of the proposals in this Consultation Paper? If not, can you provide any evidence or data that would explain why you disagree or might further inform our analysis of the likely impacts of the proposals? N/A

Upload files 150121_EACB on draft GL on contributions to DGS_final.pdf

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