Submission #7

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Building Societies Association

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. No.

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?

Yes. This option will reduce the administrative burden, and will not cause any distortion. It is essential for reasons of proportionality. The cut-off should be raised from 0.01% to 0.02%

Question 3: Can you think of any additional optional indicators that should be added to the list in Annex 2? No.

Upload files O-SII guidelines BSA Response Oct 2014.pdf

Name of organisation Building Societies Association