Submission #12

European Confederation of Institutes of Internal Auditing (ECIIA)

Q1. Do the guidelines specify the SREP process sufficiently? Are there areas where the EBA should aim for greater harmonisation, or where more flexibility would be appropriate?

We recommend to introduce the role of internal audit in the different institutions

Q2. Do you agree with the proportionate approach to the application of the SREP to different categories of institutions? (Title 2) yes

Q3. Are there other drivers of business model / strategy success and failure that you believe competent authorities should consider when conducting the BMA? (Title 4) The 3 line sof defence model should be considered

Q4. Does the breakdown of risk categories and sub-categories proposed provide appropriate coverage and scope for conducting supervisory risk assessments? (Title 6) yes

Q5. Do you agree with the use of a standard approach for the articulation of additional own funds requirements to be used by compete authorities across the Union? (Title 7) yes

Q6. Do you agree that competent authorities should be granted additional transition periods for meeting certain capital and liquidity provisions in the guidelines (Title 12)? yes

Upload files eba_final 20.doc

Name of organisation European Confederation of Institutes of Internal Auditing (ECIIA)