Submission #19

Central Bank of Ireland (Registry of Credit Unions Division)

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? N/A

Question 3: Is the proposed formula for calculating contributions to DGS sufficiently clear and transparent? N/A

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? N/A

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? N/A

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? See attached document

Upload files 2015-02-11 Central Bank of Ireland submission on EBA consultation EBA.CP.14.35 in relation to Irish Credit Unions.pdf

Name of organisation Central Bank of Ireland (Registry of Credit Unions Division)