Submission #2

Spanish Banking Association (AEB)

Question 1: Can you think of any additional indicators that should be included in Table 1 of Annex 1, or indicators that are better suited to reflect systemic relevance? Please provide evidence supporting your view where possible. Please find attached document.

Question 2: Do you agree that there may be Member States where small institutions are unlikely to pose systemic threats to the domestic economy? Do you think the option to exclude these institutions could reduce the administrative burden for institutions, or do you think there is a risk that the results of the analysis could be distorted by excluding them? Please find attached document.

Question 3: Can you think of any additional optional indicators that should be added to the list in Annex 2? Please find attached document.

Upload files AEB_Consultation Paper on EBA draft guidelines on criteria to assess other systemically important instituions__O-SIIs__17 October 2014.pdf

Name of organisation Spanish Banking Association (AEB)