Submission #23

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EACB - European Association of Co-operative Banks

1. Do you agree with the approach the EBA has proposed for the purposes of defining shadow banking entities? In particular: Do you consider that this approach is workable in practice? If not, please explain why and present possible alternatives. Do you agree with the proposed approach to the exclusion of certain undertakings,including the approach to the treatment of funds? In particular, do you see any risksstemming from the exclusion of non-MMF UCITS given the size of the industry? If youdo not agree with the proposed approach, please explain why not and present therationale for the alternative approach(es) (e.g. on the basis of specific prudentialrequirements, redemption limits, maximum liquidity mismatch and leverage etc). Please see attached paper

2. Do you agree with the approach the EBA has proposed for the purposes of establishing effective processes and control mechanisms? If not, please explain why and present possible alternatives. N/A

3. Do you agree with the approach the EBA has proposed for the purposes of establishing appropriate oversight arrangements? If not, please explain why and present possible alternatives. Please see attached paper

4.Do you agree with the approaches the EBA has proposed for the purposes of establishing aggregate and individual limits? If not, please explain why and present possible alternatives. Please see attached paper

5. Do you agree with the fallback approach the EBA has proposed, including the cases in whichit should apply? If not, please explain why and present possible alternatives. Do you think that Option 2 is preferable to Option 1 for the fallback approach? If so, why? In particular: Do you believe that Option 2 provides more incentives to gather information about exposures than Option 1? Do you believe that Option 2 can be more conservative than Option 1? If so, when? Do you see some practical Please see attached paper

6. Taking into account, in particular, the fact that the 25% limit is consistent with the currentlimit in the large exposures framework, do you agree it is an adequate limit for the fallback approach? If not, why? What would the impact of such a limit be in the case of Option 1? And in the case of Option 2? Please see attached paper

Upload files 150619_EACB comments on EBA draft GL on shadow banking exposures fin.pdf

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