In general, we agree with the scope and specification of information to be collected. Nevertheless, we note that the current information specification seems to be aiming towards a standardised information provision, which is against the EBA's intention of not specifically addressing how ICAAP/ILAAP should look like.

We agree with the general criteria for the organisation of the collection of ICAAP and ILAAP information, although we feel that in certain cases, more clarity is required on the information to be provided.