Submission #18

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EACB - European Association of Co-operative Banks

Question 1: Are you aware of any situations where the existence of a control relationship among clients does not lead to a ‘single risk’? Please see attached document.

Question 2: What is the likely impact of the clarification of having an exceptional case when the existence of a control relationship does not lead to a ‘single risk’? Please provide an estimation of the associated quantitative costs. Please see attached document.

Question 3: Do you see a need for further clarification of the accounting provisions which are relevant for large exposures purposes? If yes, please point out the exact indicator of control according to the Directive 2013/34/EU or Regulation (EC) No 1606/2002 which should be clarified with respect to the large exposures regime. Please see attached document.

Question 4: Are there any other indicators of control in the case of a similar relationship which are useful to add to this list of indicators? Please see attached document.

Question 5: What would be the cost of the assessment of the existence of control relationships in the case of subsidiaries exempted from accounting consolidation? Please provide an estimation of quantitative costs. In your experience, how significant are these cases? Please see attached document.

Question 6: Is the guidance provided in section 5. ‘Alternative approach for exposures to central governments’ clear? If not, please provide concrete suggestions. Please see attached document.

Question 7: What is the likely impact of considering that clients are connected as soon as the failure of a client would lead to ‘repayment difficulties’ of another client? Please provide an estimation of any associated quantitative costs. Please see attached document.

Question 8: Are the situations described in the list in paragraph 23 as constituting economic dependency clear? If not, provide concrete suggestions. In particular, do you have any comments regarding the introduction of the threshold of ‘at least 50%’ in points c), d), f) and g)? Please see attached document.

Question 9: Are you aware of any other situations that should be added to the list of situations that constitute economic dependency? In relation to the situation described above, would you treat these exposures as connected? Please explain. Please see attached document.

Question 10: Is the guidance in section 7. ‘Relation between interconnectedness through control and interconnectedness through economic dependency’ clear? If not, please provide concrete suggestions.What is the likely impact of this guidance? Please provide an estimation of the associated quantitative costs. Please see attached document.

Upload files EACB Comments draft EBA GL connected clients for LE_20161026.pdf

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