Submission #15

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Alberto Balestreri – Studio Balestreri & Daniela Venanzi – Dpt. of Economics, Roma Tre University

Question 1: Are there any conflicts between the responsibilities assigned by national company law to a specific function of the management body and the responsibilities assigned by the Guidelines to either the management or supervisory function? please, see the document in attachment

Question 4: Do you agree with this approach to the proportionality principle and consider that it will help in the practical implementation of the guidelines? Which aspects are not practical and the reasons why? Institutions are asked to provide quantitative and qualitative information about the size, internal organisation and the nature, scale and complexity of the activities of their institution to support their answers. please, see the document in attachment

Question 5: Do you consider that a more proportionate application of the guidelines regarding any aspect of the guidelines could be introduced? When providing your answer please specify which aspects and the reasons why. In this respect, institutions are asked to provide quantitative and qualitative information about the size, internal organisation and the nature, scale and complexity of the activities of their institution to support their answers. please, see the document in attachment

Question 6: Are the guidelines with respect to the calculation of the number of directorships appropriate and sufficiently clear? please, see the document in attachment

Question 7: Are the guidelines within Title II regarding the notions of suitability appropriate and sufficiently clear? please, see the document in attachment

Question 15: Are the guidelines within Title VII regarding the suitability assessment by competent authorities appropriate and sufficiently clear? please, see the document in attachment

Upload files EBA_suitability_consultation_balestreri_venanzi.pdf

Name of organisation Alberto Balestreri – Studio Balestreri & Daniela Venanzi – Dpt. of Economics, Roma Tre University